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

" 'Something more than the mere commission of a tort is always required for punitive damages. There must be circumstances of aggravation or outrage, such as spite or "malice," or a fraudulent or evil motive on the part of the defendant, or such a conscious and deliberate disregard of the interests of others that his conduct may be called wilful or wanton.' " (Taylor v. Superior Court (1979) 24 Cal.3d 890, 894-895.)