Unpublished opinion affirms trial court’s rejection of jury instruction limiting punitive damages to one to one ratio

It has been very quiet here lately.  We haven’t had any big verdicts, appellate decisions, legislative proposals, or law review articles to report in the past few weeks.  If you’re desperate for your fix of punitive damages news, this will have to do: in this unpublished opinion, the California Court of Appeal (Second Appellate District, Division One) held that the trial court properly refused to instruct the jury that the maximum punitive damages award was $12,250 (the amount of compensatory damages). It’s hard to argue with the court’s analysis; there isn’t any law that would impose a one-to-one ratio with a compensatory damages award of that size.  The defendant was clearly over-reaching by requesting that instruction.