The California Court of Appeal (Second District, Division Seven) issued this unpublished opinion today, reversing a $1.15 million punitive damages award and a $230,000 compensatory damages award.

In the interests of full disclosure, our firm represented the defendant. We raised a few interesting punitive damages questions (e.g., whether a $230,000 compensatory damages award is “substantial” within the meaning of State Farm v. Campbell, such that the ratio of ratio of punitive to compensatory damages should not exceed 1-to-1). The court did not reach those issues; it reversed the entire judgment because the plaintiff failed to prove causation.