Kozicki v. Craig: Unpublished Opinion Reduces $100,000 Punitive Damages Award to $3,600

The California Court of Appeal (Fourth District, Division One) issued this unpublished opinion reducing a punitive damages award in an appeal from a default judgment. The court concluded that the record would not support a punitive damages award more than $3,600 – – six times the compensatory damages of $600. The court did not invoke the U. S. Supreme Court’s statement in State Farm v. Campbell that the ratio of punitive damages to compensatory damages can exceed single digits in cases involving “unusually small” compensatory damages.