This unpublished opinion is the latest in a long string of California appellate decisions reversing a punitive damages award because the plaintiff failed to present complete evidence of the defendant’s financial condition.

The plaintiff presented evidence of the defendant’s income, but no evidence of the defendant’s liabilities or expenses. Many trial lawyers seem to think that’s good enough. It isn’t. As the Court of Appeal explained: ” ‘Normally, evidence of liabilities should accompany evidence of assets, and evidence of expenses should accompany evidence of income.’ ” Because plaintiff failed to carry its burden of proof on this issue, the Court of Appeal directed the trial court to enter judgment for the defendant on the claim for punitive damages.