$25,000 in punitive damages reversed due to lack of evidence of financial condition (Allen v. Packer)

In this unpublished opinion, the California Court of Appeal (Second Appellate District, Division One) adds to the long line of decisions reversing a punitive damages award because the plaintiff failed to present meaningful evidence of the defendant’s financial condition.  Here, the record contained evidence of gross revenues, but nothing about the defendant’s expenses and liabilities.