“Published opinion exacerbates split over application of clear-and-convincing evidence standard on appeal”

The Horvitz & Levy blog “California Punitive Damages” reports on a published Court of Appeal opinion — Morgan v. Davidson — that the blog says “may cause the California Supreme Court to finally settle a long-simmering split of authority” regarding what effect, if any, the clear-and-convincing standard of proof at trial has on the standard of appellate review in punitive damages cases.