In this unpublished opinion, the California Court of Appeal (Second Appellate District, Division Two) affirms a $1.5 million punitive damages award without much discussion.

The court says that the appellant’s counsel waived a challenge to the evidence supporting the punitive damages award because the argument was asserted “perfunctorily asserted in two sentences in Caitac’s opening brief.” The court goes on to say that, even if the appellant had not waived the argument, the court would have upheld the punitive damages award because there was sufficient evidence that the defendant acted with conscious disregard of the plaintiff’s rights.