What is the test for punitive damages in a wrongful termination case?

MultiRegion, United States of America

The following excerpt is from Lambert v. Ackerley, 180 F.3d 997 (9th Cir. 1998):

There is no dispute that Washington law does not allow for punitive damages in wrongful termination cases, see Dailey v. North Coast Life Ins. Co., 129 Wash.2d 572, 919 P.2d 589 (1996); therefore, the punitive damages award should be reversed.

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