The California Court of Appeal (Second Appellate District, Division Four) has ordered publication of this previously unpublished opinion we blogged about a few weeks ago.  The Court of Appeal’s online docket says publication was requested by the plaintiff and by “Non-parties Brakefield.”  I’m not sure who or what Brakefield is, but presumably they’re seeking punitive damages in some other action and they sought publication of this opinion to chip away at the usual strict standards for punitive damages claims in California.