I’ve been catching up on some unpublished punitive damages opinions that were issued earlier this year. Here’s a brief rundown:

Matthes v. Rodgers (May 13, 2024, Second District, Division Four):

Upholding $1.95 million in punitive damages; defendant failed to respond to subpoenas requesting financial information, and therefore waived its right to complain that trial court erred when it modified the standard CACI instructions to delete the language telling the jury to consider the defendant’s ability to pay

Soria v. Compass Group (April 16, 2024, Second District, Division Two):

Holding that trial court properly granted nonsuit on punitive damages because plaintiff failed to present evidence that two employees of defendant hospital were managing agents

Medel v. Oceanic Companies (February 22, 2024, Fourth District, Division One):

Holding that trial court properly reduced $2 million and $1 million punitive damages awards to $652,000 and $326,000 (ratios of two-to-one and one-to-one) for conduct that was “moderately to highly reprehensible”

Rudnicki v. Farmers Insurance Exchange (January 2, 2024, Second District, Division Two)

Declining to further reduce punitive damages that trial court cut from $150 million to $18.5 million (3.5-to-one ratio) in retaliation case involving “moderately reprehensible” conduct