The following excerpt is from O'Keefe v. Brown, No. 2:11-cv-2659 KJM KJN P (E.D. Cal. 2017):
The standard for punitive damages requires a showing that "the defendant's conduct is . . . motivated by evil motive or intent, or when it involves reckless or callous indifference to the federally protected rights of others." Smith v. Wade, 461 U.S. 30, 56 (1983).
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