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California Court of Appeal

Tran v. Lecong: $100,000 in punitive damages vacated due to lack of meaningful financial condition evidence

April 7, 2011

Here we go again: this unpublished opinion from the California Court of Appeal (Second Appellate District, Division Five) reverses a punitive damages award because the plaintiff failed to introduce meaningful evidence of the defendant’s financial condition. “There is little evidence of [defendant]’s actual assets or income and no evidence of his liabilities. . . . Accordingly, the punitive damage award is reversed and retrial is unnecessary.” 

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