What is the test for assessing punitive damages in a motor vehicle accident case?

Reed also contends that, applying the federal due process guideposts for assessing punitive damages, his conduct was not sufficiently reprehensible to support the jury's award of punitive damages. Of the three guideposts, " 'the most important is the degree of reprehensibility of the defendant's conduct. On this question, the high court instructed courts to consider whether "[1] the harm caused was physical as opposed to economic; [2] the tortious conduct evinced an indifference to or a reckless disregard of the health or safety of others; [3] the target of the conduct had financial vulnerability; [4] the conduct involved repeated actions or was an isolated incident; and [5] the harm was the result of intentional malice, trickery, or deceit, or mere accident." ' " (Bankhead v. ArvinMeritor, Inc., supra, 205 Cal.App.4th at p. 85.)