What is the test for overturning a jury's award of punitive damages?

We will address the cross-appeal first. Plaintiff contends that the issue before us is whether the jury's award of punitive damages exceeded constitutional limits. She argues that we should exercise our independent judgment on that question and, if we conclude the original jury award fell within constitutional limits, reinstate that award. (See Johnson v. Ford Motor Co. (2005) 35 Cal.4th 1191, 1201 [court reviewing award of punitive damages for constitutionality makes independent assessment of relationship between award and factual circumstances of case].)