What is the test for punitive damages in a workplace injury case?

Punitive damages also may be supported by uncontradicted evidence that a plaintiff was damaged by a defendant's tortious act. For example, in Wayte, a worker, his spouse and dependent adult son sued the employer for retaliatory termination after the worker resisted the employer's decision to exclude the dependent son from the worker's employer-sponsored health insurance policy. (Wayte v. Rollins, supra, 169 Cal.App.3d at pp. 8-9.) The jury awarded compensatory damages to the worker and his spouse, and

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