This unpublished opinion is yet another reminder that in California, plaintiffs cannot obtain punitive damages without presenting meaningful evidence of the defendant’s financial condition, even in the case of a default judgment.   

In this case, the plaintiff obtained a default judgment and, at a prove up hearing, presented evidence of its damages.  But it presented no evidence of the defendant’s financial condition.  Accordingly, the California Court of Appeal (Fourth Appellate District, Division One) ordered the trial court to strike the award of punitive damages from the judgment.