What is our standard of review in cases involving punitive damages?

California, United States of America


The following excerpt is from Yankey v. City of L. A., B257780 (Cal. App. 2015):

That the standard of proof at the trial level was by clear and convincing evidence does not change our standard of review. Even in cases involving punitive damages where we are instructed to pay "due attention to the heightened standard of proof," we nevertheless "review the evidence in the light most favorable to the [prevailing party], give them the benefit of every reasonable inference, and resolve all conflicts in their favor[.]" (Pfeifer v. John Crane, Inc. (2013) 220 Cal.App.4th 1270, 1299.) "When there is substantial evidence to support the jury's actual conclusion, 'it is of no consequence that the [jury] believing other evidence, or drawing other reasonable inferences, might have reached a contrary conclusion.' [Citation.]" (Id. at p. 1301.)

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