What is the test for punitive damages in a civil case brought by a plaintiff against a defendant for failing to protect her from the effects of abortion?

MultiRegion, United States of America

The following excerpt is from Logue v. Curtis Mgmt. Co., Case No. 19-cv-189-BAS-NLS (S.D. Cal. 2019):

Under federal law, punitive damages may be awarded for a defendant's "reckless or callous disregard" of a plaintiff's federally protected rights. Smith v. Wade, 461 U.S. 30, 51 (1983). A finding of reckless indifference "ultimately

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