Rubio v. CIA Wheel Group
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The Court of Appeal affirmed the trial court's judgment entered against defendants after a bench trial in a wrongful termination action brought by a former employee. The employee alleged, inter alia, that CWG terminated her in violation of public policy because she had cancer.
The court concluded that the $500,000 punitive damages award is not constitutionally excessive. In this case, the trial court properly considered harm to the employee beyond her economic damages; there are no comparable civil penalty provisions; defendants' conduct was reprehensible; and the punitive damages award is constitutionally permissible given the reprehensibility of defendants' conduct and the emotional harm to plaintiff. The court also concluded that defendants have not shown that the punitive damages are excessive under California law. The court further concluded that defendants have forfeited their claim that the trial court erred in considering Holdings's financial condition in assessing punitive damages. Finally, defendants have forfeited their claims based on Civil Code section 3294.
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