BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 840
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          Date of Hearing:   April 24, 2001

                           ASSEMBLY COMMITTEE ON JUDICIARY
                              Darrell Steinberg, Chair
             AB 840 (Robert Pacheco) - As Introduced:  February 22, 2001
           
          SUBJECT  :   PUNITIVE DAMAGES CAP FOR SMALL BUSINESS DEFENDANTS

           KEY ISSUES  :

          1)SHOULD THE TRADITIONAL RIGHT OF JURORS TO DETERMINE IF A  
            DEFENDANT'S CONDUCT WAS SO OPPRESSIVE, FRAUDULENT OR MALICIOUS  
            SO AS TO REQUIRE SUBSTANTIAL PUNITIVE DAMAGES BE SEVERELY  
            CURTAILED IN ALL CASES WHERE DEFENDANTS APPEAR TO FIT WITHIN  
            THE DEFINITION OF  "SMALL BUSINESS" UNDER FEDERAL REGULATIONS?

          2)SHOULD THE LEGISLATURE CODIFY, FOR "SMALL BUSINESS" DEFENDANTS  
            ONLY, THE CONCURRING OPINION OF SUPREME COURT JUSTICE JANICE  
            ROGERS BROWN LAST YEAR IN THE CASE OF LANE V. HUGHES AIRCRAFT,  
            WHEREBY THE JUSTICE ARGUES "PUNITIVE DAMAGES SHOULD RARELY  
            EXCEED COMPENSATORY DAMAGES BY MORE THAN A FACTOR OF THREE"?   
            WOULD THE APPROACH ADVOCATED BY JUSTICE ROGERS BROWN IN HER  
            CONCURRING OPINION IN LANE CONSTITUTE A "BRAND OF JUDICIAL  
            LAWMAKING," AS SUGGESTED BY JUSTICE MOSK IN THE SAME CASE? 

          3)MIGHT THE BILL'S PROPOSED SPECIAL "CARVE-OUT" INADVERTENTLY  
            SEND THE MESSAGE THAT IN CALIFORNIA IT IS MORE ACCEPTABLE FOR  
            SMALL BUSINESSES TO ENGAGE IN OPPRESSIVE, FRAUDULENT OR  
            MALICIOUS CONDUCT THAN IT IS FOR OTHERS?

          4)SHOULD PUNITIVE DAMAGE AWARDS THAT EXCEED THREE TIMES THE  
            AMOUNT OF COMPENSATORY DAMAGES IN NON-SMALL BUSINESS CASES BE  
            SUBJECT TO A TOUGHER STANDARD OF REVIEW, CONSTITUTING A NEW  
            STATE POLICY THAT LARGE PUNITIVE DAMAGE AWARDS ARE DISFAVORED  
            REGARDLESS OF HOW OUTRAGEOUS THE PARTICULAR MISCONDUCT? 

          5)IS THERE SUFFICIENT EVIDENCE OF ABUSE BY JURIES IN THE  
            AWARDING OF PUNITIVE DAMAGES AGAINST SMALL BUSINESSES IN  
            CALIFORNIA TO SUPPORT VITIATING THE LONG-STANDING RIGHT VESTED  
            IN JURIES TO COMPETENTLY MAKE THESE DECISIONS?

                                      SYNOPSIS

          This Bill Continues A Long Tradition By Some Business Groups In  
          California To Try To Restrict The Historical Right Of  








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          Californians Serving On Juries To Determine The Appropriate  
          Amount Of Punitive Damages In The Rare Cases Where Punitive  
          Damages Are Deemed Necessary.  Contrary To Last Year's Effort To  
          Limit The Right Of Juries To Award Punitive Damages In All  
          Cases, This Legislation Seeks To Limit Jury Authority In This  
          Area Solely For Those Defendants That Meet Federal Regulations  
          Classifying "Small Businesses."  For Such Small Business  
          Defendants Alone, Potential Punitive Damages Will Be Capped At 3  
          Times The Compensatory Damages, Regardless Of How Oppressive,  
          Fraudulent Or Malicious Their Conduct.  This Approach Thereby  
          Essentially Codifies For Small Business Defendants The  
          Concurring Opinion By California Supreme Court Justice Janice  
          Rogers Brown In Last Year's Case Of  Lane V. Hughes Aircraft  .  

          In Addition To Creating A Special Punitive Damages "Carve Out"  
          For Small Business Defendants, This Bill Also Seeks To Reduce  
          The Imposition Of Substantial Punitive Damage Awards Against  
          Larger Business Defendants Through The Use Of A Much Stricter  
          Standard Of Appellate Review.  The Bill Seeks To Do This By  
          Requiring That Any Punitive Damages Found Appropriate By A Jury  
          Which Exceed Justice Rogers Brown's Proposed Judicial Policy Of  
          "3 Times Compensatories" Must Be Reviewed "De Novo," Requiring  
          Appellate Courts To Substitute Their Own Judgment For That Of  
          The Jury As To The Correct Amount Of Punitive Damages.   
          Currently All Punitive Damage Awards In California Assessed By  
          Juries Face A More Deferential Standard Of Review, Whereby  
          Appellate Courts Ensure That There Is "Clear And Convincing"  
          Evidence Supporting The Jury's Punitive Damages Determination.    
           

           SUMMARY  :  Essentially codifies the concurring opinion of  
          California Supreme Court Justice Janice Rogers Brown in last  
          year's case of  Lane v. Hughes Aircraft  , whereby the Justice  
          argues that the courts should adopt a public policy generally  
          limiting punitive damage awards in California to three times the  
          compensatory damages awarded.  Specifically,  this bill  :

          1)Seeks to curtail the traditional right and responsibility of  
            California jurors to determine appropriate levels of punitive  
            damage awards by arbitrarily capping at "3 times  
            compensatories" all such awards for small business defendants,  
            irrespective of how oppressive, fraudulent or malicious the  
            conduct involved, thereby codifying for small business  
            defendants alone the concurring opinion of California Supreme  
            Court Justice Janice Rogers Brown in  Lane v. Hughes Aircraft  .








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          2)Seeks to reduce the size of punitive damage awards imposed  
            against larger business defendants by requiring that any  
            punitive damages found appropriate by California jurors which  
            exceed Justice Rogers Brown's proposed policy cap of "3 times  
            compensatories" be subjected to de novo appellate review,  
            whereby the appellate court must review the evidence in the  
            case anew, and substitute its own determination for that of  
            the jury as to the correct amount of punitive damages.

           EXISTING LAW  :

          1)Provides for the award of punitive damages in addition to  
            actual damages in cases not arising in contract (i.e., tort  
            cases) "for the sake of example and by way of punishing the  
            defendant":  (a) when it is proven by clear and convincing  
            evidence; and (b) where the defendant is guilty of oppression,  
            fraud, or malice.  (Civil Code Section 3294(a).  All further  
            statutory references are to this code unless otherwise  
            stated.)

          2)Defines, for the purpose of determining punitive damages, the  
            following key terms:

             a)   "Malice" means conduct which is intended to cause injury  
               or despicable conduct with a willful and conscious  
               disregard of the rights or safety of others.

             b)   "Oppression" means despicable conduct that subjects a  
               person to cruel and unjust hardship in conscious disregard  
               of that person's rights.

             c)   "Fraud" means an intentional misrepresentation, deceit,  
               or concealment of a material fact known to the defendant  
               with the intention of depriving a person of property or  
               legal rights or otherwise causing injury.  (Section  
               3294(c).)

          3)Provides for punitive damages in wrongful death actions  
            against persons convicted of homicide.  (Section 3294(d).)

          4)Authorizes courts to grant a defendant a protective order  
            requiring the plaintiff to produce evidence of a prima facie  
            case of liability for punitive damages prior to introducing  
            evidence of the defendant's profits or financial condition.   








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            (Section 3295(a).)

          5)Precludes the plaintiff from pretrial discovery of evidence of  
            defendant's profits or financial condition, unless the court  
            determines that the plaintiff has established that there is a  
            substantial probability that the plaintiff will prevail on the  
            claim for punitive damages.  (Section 3295(c).)

          6)Prohibits the admission of evidence of a defendant's profits  
            or financial condition until after the trier of fact returns a  
            verdict for the plaintiff awarding actual damages and finds  
            that a defendant is guilty of malice, oppression or fraud  
            entitling the plaintiff to punitive damages.  (Section  
            3295(d).)

          7)Precludes a claim for punitive damages from stating an amount.  
             (Section 3295(e).)

          8)Requires, pursuant to SB 241 (Lockyer, Ch. 1498 of 1988), that  
            a jury's punitive damages determination be reviewed on appeal  
            solely to confirm that there was "clear and convincing"  
            evidence supporting the jury's punitive damages determination.  
             (Section 3294(a).)  Prior to SB 241, a mere preponderance of  
            the evidence was required to support a punitive damages award.

           FISCAL EFFECT  :   As currently in print this bill is keyed  
          non-fiscal.

           COMMENTS  :  This bill continues a long line of similar bills  
          sponsored by the Civil Justice Association of California (CJAC -  
          formerly the Association for California Tort Reform) seeking to  
          curtail the right of California jurors to determine when, and to  
          what extent, punitive damages are necessary to punish  
          particularly egregious acts and deter the commission of wrongful  
          acts in the future.

          The author wrote the following statement in support of the bill:

               AB 840 addresses serious concerns of California's  
               small businesses.  The threat of a large punitive  
               damage award against a small business has created a  
               situation where small businesses will settle lawsuits  
               for large sums of money rather than risk a punitive  
               damage award that could bankrupt the business.  Small  
               businesses employ a majority of Californians, operate  








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               on small profit margins and therefore deserve  
               protection.  AB 840 simply gives a limited measure of  
               protection to a small business without limiting any  
               amount a plaintiff can recover for their damages plus  
               pain and suffering.  In a time when small businesses  
               are being squeezed by higher energy costs, rising  
               salaries and greater regulatory burdens, protection  
               from excessive penalties is appropriate.

           Background  :  In civil law, the term "damages" refers to the  
          monetary sum assessed by a court against a wrongdoer.  The  
          primary objective of an award of damages in a civil action is  
          just compensation for the actual loss or injury sustained by the  
          complaining party.  These are called "actual" or "compensatory"  
          damages.  "Punitive damages," also referred to as "exemplary  
          damages," are seldom awarded, and when they are they are awarded  
          for the sake of example and to punish a defendant who has been  
          found to meet a strict legal standard of "outrageous" conduct.   
          Traditionally, punitive damages must bear a reasonable  
          relationship to the damage actually sustained by the plaintiff.   
          But there has never been any statutory ratio in California  
          jurisprudence arbitrarily limiting a jury's right to decide the  
          appropriate level of punitive damages when they are deemed  
          necessary.

           Overview Of California Case Law  :  The purposes of punitive  
          damages are to punish wrongdoers and to deter future misconduct  
          by making an example of the defendant.  (  PPG Industries v.  
          Transamerica Ins. Co.  (1999) 20 Cal.4th 310, 317.)  However,  
          there is no right to punitive damages.  (  Hannon Engineering v.  
          Reim  (1981) 126 CalApp.3d 415.)  Punitive damages are merely  
          incident to the underlying cause of action.  (  James v. Public  
          Finance  (1975) 47 Cal.App.3d 995.)  Nor may punitive damages be  
          awarded unless actual damages are suffered.  (  A. Esparza v.  
          Specht  (1976) 55 Cal.App.3d 1.)
           
          Historically, the propriety and amount of punitive damages is  
          within the discretion and province of the jury.  (  Fenlon v.  
          Brock  (1989) 216 Cal.App.3d 1174.)  However, when an award of  
          punitive damages is excessive or is so grossly disproportionate  
          as to raise a presumption that it is the result of passion or  
          prejudice, an appellate court will reverse the award.  (  Godfrey  
          v. Steinpress  (1982) 128 Cal.App.3d 154.)  In determining the  
          amount of a punitive damages award, guidance is provided by the  
          amount of compensatory damages, the wealth of the particular  








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          defendant and the particular nature of the defendant's acts in  
          light of the whole record.  (  Neal v. Farmers Insurance Exchange   
          (1978) 21 Cal.3d 910.)

           Overview of U.S. Supreme Court Cases  :  In  BMW of North America,  
          Inc. v. Gore (1996) 517 U.S. 559, the Supreme Court, in a 5-4  
          decision, held that:  (a) a $2 million punitive damages award  
          was grossly excessive in relation to a state's legitimate  
          interests in punishing unlawful conduct and deterring its  
          repetition, and therefore exceeds constitutional limits in  
          violation of due process; (b) elementary notions of fairness  
          dictate that a person receive fair notice of the conduct that  
          will subject him to punishment as well as the severity of the  
          penalty the state may impose; and (c) a punitive damages award  
          that is 500 times the amount of actual damages is clearly  
          outside the acceptable range.  However importantly in the  
          context of this legislative proposal, the U.S. Supreme Court  
          also held that it is not possible to draw a mathematical bright  
          line between a constitutionally acceptable and constitutionally  
          unacceptable formula that will fit every case.  
           
          In two previous cases,  Pacific Mutual Life Insurance Company v.  
          Haslip  (1991) 499 U. S. 1 and  TXO Production Corp. v. Alliance  
          Resources Corp.  (1994) 509 U.S. 443, the Supreme Court had  
          endorsed the principle that exemplary damages must bear a  
          "reasonable relationship" to compensatory damages.  In  TXO  , the  
          Court stated that the proper inquiry is "whether there is a  
          reasonable relationship between the punitive damages award and  
          the harm likely to result from the defendant's conduct as well  
          as the harm that actually has occurred."  (509 U.S. at 460.)

           Current California Supreme Court Doctrine on the Role and Scope  
          of Punitive Damages  :  In 1978, the California Supreme Court set  
          forth its definitive review to date of the role and scope of  
          punitive damages.  In  Neal v. Farmers Ins. Exchange  (1978) 21  
          Cal.3d 910, the Court stated that "The purpose of punitive  
          damages is to punish wrongdoers and thereby deter the commission  
          of wrongful acts."  (21 Cal.3d at 928, fn. 13.)  In that case,  
          an injured motorist sued for compensatory and punitive damages  
          for the bad faith failure of her insurance company to pay  
          uninsured motorist benefits to her under her policy, and the  
          jury returned an undifferentiated verdict in her favor for about  
          $1.5 million.  In upholding the award, the Supreme Court set  
          forth three factors relevant to the assessment of punitive  
          damages:  (1) the degree of reprehensibility of the act; (2) the  








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          amount of compensatory damages awarded; and (3) the wealth of  
          the particular defendant.  (Id. at 928.)  
           
           The Unusual "Double Opinion" of Justice Janice Rogers Brown in  
          Lane v. Hughes Aircraft:   Not all justices on the Supreme Court  
          continue to agree with the statements made by the state Supreme  
          Court in the 1978  Neal  decision, however.  Just last year, in  
           Lane v. Hughes Aircraft  (2000) 22 Cal.4th 405, in an unusual  
          situation Justice Janice Rogers Brown wrote both a majority and  
          concurring opinion in the same case.  While the majority opinion  
          did not address the issue of punitive damages, since it was not  
          the issue being decided by the Court, Justice Rogers Brown felt  
          compelled to write a separate concurring opinion, joined in by  
          Justice Chin, setting forth her policy thoughts regarding how  
          courts in California should regulate jury decisions regarding  
          punitive damages.

          In her concurrence in  Lane  , Justice Rogers Brown wrote:

               I, of course, agree with the majority opinion [which I  
               wrote] as far as it goes.  I write separately to  
               address the punitive damages issue in greater detail?.  
               The Legislature has expressly authorized trial courts  
               to grant new trials when damages are "excessive"  
               [citation omitted], and the trial court here granted a  
               new trial as to punitive damages on that ground.  Our  
               role as the final interpreter of state law obligates  
               us to give meaning to the term 'excessive' in relation  
               to punitive damages. ? We must ask what anchoring  
               variable will make an award of punitive damages an  
               appropriate measure of punishment rather than a test  
               of a jury's ability to imagine big numbers?  In the  
               case of large awards, punitive damages should rarely  
               exceed compensatory damages by more than a factor of  
               three, and then only in the most egregious  
               circumstances clearly evident in the record.  In  
               arguing for this standard, I do not mean to suggest  
               that three times compensatory damages is a benchmark  
               measure of punitive damages.  [citation omitted].  Far  
               from it.  The standard is an uppermost limit, and most  
               punitive damage awards should fall well below that  
               limit.   (22 Cal.4th at 422-23.)  (emphasis added.)
           
          Justice Mosk's Concurring Response in Lane v. Hughes Aircraft  :   
          In a separate concurrence, Justice Stanley Mosk wrote "to  








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          disagree with the views expressed in Justice Brown's concurring  
          opinion."  (Id. at 416.)  Justice Mosk then stated:

               Although no measure adopted by the Legislature so  
               provides, the concurring opinion advocates a brand of  
               judicial lawmaking by declaring that punitive damages  
               must not, absent some special, unspecified showing,  
               exceed actual damages by more than three times.  Such  
               a rule cannot be justified.  'The purpose of punitive  
               damages is to punish wrongdoers and thereby deter the  
               commission of wrongful acts.'  (Citing  Neal  , supra.)   
               The concurring opinion proposes to fix a 'soft'  
               ceiling on punitive damages by using only one of the  
               three  Neal  factors-the amount of compensatory damages.  
                But the primary purpose of compensatory damages is  
               fundamentally different from punitive damages-to make  
               plaintiffs whole, not to deter future harm. There is  
               simply no reason why punitive damages should be  
               limited by some fixed ratio to actual damages.

               What the United States Supreme Court stated in the  
               context of a due process analysis of punitive damages  
               is directly relevant here:  '[W]e have consistently  
               rejected the notion that the constitutional line [for  
               limiting punitive damages] is marked by a simple  
               mathematical formula, even one that compares actual  
               and potential damages to the punitive award.   
               [Citation omitted.]  Indeed, low awards of  
               compensatory damages may properly support a higher  
               ratio than high compensatory awards, if, for example,  
               a particularly egregious act has resulted in only a  
               small amount of economic damages.  A higher ratio may  
               also be justified in cases in which the injury is hard  
               to detect or the monetary value Citing of non-economic  
               harm might have been difficult to determine.'  (Citing  
                BMW of North America, Inc. v. Gore  (1996) 517 U.S.  
               559, 582.)  Given that the 'simple mathematical  
               formula' has been rejected in the constitutional  
               context because it is illogical, and given that no  
               such formula has been dictated by statute, it is  
               difficult, to say the least, to see why we should  
               impose the rule by judicial fiat, as the concurring  
               opinion proposes.  (Emphasis added.)
           
          New Standard of Review  :  In addition to capping punitive damage  








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          awards for small businesses, this legislation also seeks to  
          impose the toughest standard of review on large punitive damages  
          awards, requiring de novo review for any punitive damage award  
          exceeding three times compensatories.  In support of this  
          proposed heightened scrutiny, CJAC argues that the bill "does  
          not require an appellate court to lower the punitive damage  
          award, it simply allows another court to review the existing  
          record to ensure the award meets existing standards of fairness.  
           This is the current standard set forth by the United States  
          Supreme Court under BMW v. Gore (1996) and the current practice  
          in some parts of California."  CJAC further states that the  
          California Supreme Court's decision in McCoy v. Hearst Corp.  
          (1986) 42 C.3d 835, 842, may even require the bill's proposed  
          heightened level of review.  However that case merely held that  
          independent appellate review of the record is required under  
          federal constitutional law in cases implicating constitutional  
          rights, not in all cases where punitive damages are awarded. 

          CJAC also asserts that some appellate districts have required  
          independent review of punitive damage awards, citing Stewart v  
          Truck Insurance Exchange, 17 Cal. App. 4th 468 (1993).  However  
          an independent review of that case suggests that assertion may  
          not be correct.  In that 1993 case, the court instead merely  
          noted that since 1988, "a claim for punitive damages has  
          required evidence which establishes by 'clear and convincing  
          evidence' that the defendant has been 'guilty of oppression,  
          fraud, or malice.... We see no reason why this standard should  
          not apply here."  (Id. at 482, emphasis added.)  However CJAC  
          appears to confuse the holding in Stewart.  By stating that  
          since 1998 appellate courts in California must ensure that there  
          was "clear and convincing" evidence supporting a jury's punitive  
          damages award, it is not clear this court was stating de novo,  
          or independent, appellate review was required.  These are two  
          different issues. 

          In addition, it should be noted that Justice Janice Rogers Brown  
          herself has, in the majority opinion in the Lane case, noted the  
          benefits of the current more deferential standard of appellate  
          review of such awards.  Writing for the majority in Lane,  
          Justice Rogers Brown gave these reasons for supporting such  
          judicial deference:  "The trial court sits much closer to the  
          evidence than an appellate court.  Even the most comprehensive  
          study of a trial court record cannot replace the immediacy of  
          being present at the trial, watching and hearing as the evidence  
          unfolds.  The trial court, therefore, is in the best position to  








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          assess the reliability of a jury's verdict and, to this end, the  
          Legislature has granted trial courts broad discretion to order a  
          new trial."  (Lane, supra, at page 412.)  

          The de novo review contemplated in AB 840, however, would  
          require an appellate court to substitute its judgment, far  
          removed from a trial, for that of a trial court.  Such an  
          approach would seemingly undercut the purpose described by  
          Justice Janice Rogers Brown of trial by jury, and the jury's  
          power to award an appropriate measure of punitive damages  
          without arbitrary caps.  
           
           The Ambiguity Surrounding the Definition of "Small Business:  "   
          Stating that this bill "proportionalizes punitive damages,  
          limiting them to three times compensatory damages for small  
          businesses only," the bill's sponsor states that "small business  
          is defined in AB 840 using current definitions set forth under  
          the Small Business Administration Act."  However a review of  
          this Act suggests that it will not always be clear whether a  
          particular business would or would not be eligible for the  
          "small business" punitive damages limitation, and how and  when   
          the court would make that determination.   

          As the Consumer Attorneys of California (CAOC) note, many of the  
          over 300,000 manufacturing companies in the U.S. are businesses  
          of 25 employees or fewer, according to the Small Business  
          Administration (SBA).  Moreover, the SBA regulations defining a  
          small business (which form the definition of a small business in  
          AB 840) show that "small businesses" are sometimes anything but  
          small.  Part 121 of Title 13 of the Code of Federal Regulations  
          contains the size standards that define whether a business  
          entity is small.  The SBA considers many factors in its  
          determination and sets industry specific standards.  For  
          example, according to CAOC, "an oil and gas exploration company  
          with less than $5 million in sales is a small business.  A  
          petroleum refining company with less than 1500 employees is  
          small.  An asbestos manufacturer employing less than 750  
          employees is small.  Tire companies employing less than 1000 is  
          considered small.  Put another way, a petroleum refining company  
          with 1499 employees that poisons a neighborhood water system is  
          a small business for purposes of AB 840 and would never be fully  
          accountable for the harm caused to a community."  
            
          Recent Legislative Reforms Of Punitive Damages  :  The original  
          punitive damages statute was enacted in California in 1872.  In  








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          recent years, there have been a series of procedural  
          modifications to punitive damages determinations:
           
          In 1979, SB 227 (Robbins) granted defendants the authority to  
          obtain a protective order requiring the plaintiff to produce  
          evidence of a prima facie case of liability for punitive  
          damages, prior to introducing evidence of the defendant's wealth  
          or profits.
           
          In 1980, SB 1242 (Maddy):  (a) established the specific  
          definitions of "malice, oppression, and fraud" which appear in  
          the punitive damages section; (b) provided that an employer is  
          not liable for punitive damages for an act of an employee unless  
          the employer had advance knowledge of the unfitness of the  
          employee and employed him or her with a conscious disregard of  
          the rights or safety of others, or authorized or ratified the  
          wrongful conduct; and (c) precluded pretrial discovery as to  
          profits and financial condition unless the court first  
          determined that a plaintiff had established a substantial  
          probability that the plaintiff would prevail on the claim for an  
          award of punitive damages.
           
          In 1987, SB 241 (Lockyer) required proof of malice, oppression  
          or fraud by clear and convincing evidence, instead of by a mere  
          preponderance of the evidence.

           Recent Studies Show Punitive Damages Awards Are Rare  :  According  
          to statistics provided to the Committee by CAOC, a number of  
          recent studies appear to demonstrate that punitive damages  
          awards are actually infrequent, contrary to widespread public  
          opinion.  The Wall Street Journal reported on July 16, 1996, on  
          a punitive damages study that was conducted by the National  
          Center for State Courts.  The Journal reported:  "Punitive  
          damages are generally modest, and meted out in only the most  
          extreme circumstances. ? According to the study, most punitive  
          awards aren't random, as critics have argued, but instead are  
          closely tailored to the amount of compensatory damages, such as  
          medical expenses and lost wages."

          According to CAOC, a U.S. Department of Justice study analyzing  
          civil jury cases over a 12-month period in the nation's most  
          populous counties found that juries awarded punitive damages in  
          only 6% of all successful suits, and that approximately half of  
          these punitive damage awards were for $50,000 or less.   
          Similarly, a recent study by the American Bar Foundation found  








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          that punitive damages are awarded in less than 5% of civil jury  
          verdicts in its review of 25,000 verdicts in eleven states over  
          a four year period.  CAOC also points to a recent study by the  
          RAND Institute for Civil Justice which reportedly shows that  
          punitive damages were awarded in only 2% of successful verdicts.

           National Center for State Courts Study  :  The Wall Street Journal  
          reported on July 16, 1996, on a punitive damages study that was  
          conducted by the National Center for State Courts.  The Journal  
          reported:

          ? Punitive damages are generally modest, and meted out in only  
            the most extreme circumstances. ? According to the study, most  
            punitive awards aren't random, as critics have argued, but  
            instead are closely tailored to the amount of compensatory  
            damages, such as medical expenses and lost wages.

          ? Plaintiffs were awarded punitive damages in just 6% of the  
            jury verdicts in which the plaintiffs prevailed.   Because  
            plaintiffs succeeded about half the time, punitive damages  
            were awarded in just 3% of all jury trials  .  (Emphasis added.)

          ? In 2,849 trials won by plaintiffs, there was a mean  
            compensatory damages award of $386,000.  In those cases, 177  
            punitive damages awards also were meted out, with a mean of  
            $534,000.

           ARGUMENTS IN SUPPORT  :  In support of this bill, the Civil  
          Justice Association of California (CJAC) writes that a new study  
          released last week by McGeorge School of Law Professor J. Clark  
          Kelso "confirms the escalation of punitive damages awarded in  
          California."  CJAC states that the study identifies three main  
          points:

               First, there is an increase in punitive damage awards  
               during the 1990s.  Second, in cases where punitive  
               damages are awarded, punitive damages account for an  
               overwhelming proportion of all damages awarded, more  
               than 7.5 times greater than the total amount of  
               compensatory damages awarded.  Finally, the study  
               found that regardless of the defendant, the type of  
               case, or size of award, there are high multiple  
               punitive damage awards across the spectrum, but most  
               notably in a distinctive set of 'high punitive damage  
               cases' ('HPDCs').  In these 'high punitive damage  








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               cases,' the average punitive awards and the ratio  
               between the punitive and compensatory awards are  
               substantially greater than in non-HPDC cases. 

          CJAC also writes that increasing punitive damage awards lead to  
          greater numbers of demands for punitive damages.  They cite a  
          Washington Legal Foundation (WLF) study involving the incidence  
          of demands for punitive damages in lawsuits filed in various  
          California counties, which apparently found the following: 

               In San Diego, punitive damages were demanded in 60% of the  
               tort and contract suits against government entities, 41% of  
               the suits against businesses, and 26% of the suits filed  
               against individuals.  In Los Angeles county, the  
               percentages were 36% in lawsuits filed against government  
               entities, 50% of the suits against businesses, and 20% of  
               the suits filed against individuals.  (Citing Legal  
               Backgrounder, Washington Legal Foundation, Vol. 12 No. 2,  
               February 1997.) 

           ARGUMENTS IN OPPOSITION  :  Consumer Attorneys of California  
          (CAOC) strongly opposes the bill, stating that AB 840 would  
          arbitrarily limit the amount of punitive damages in an action  
          against a "small" business and change the standard of appellate  
          review for punitive damages.
          CAOC writes:

               Limiting punitive damages to an arbitrary level would  
               undercut their deterrent value since businesses might  
               find it cheaper and more cost effective to continue  
               their bad behavior and to risk paying punitive  
               damages? As Justice Mosk noted in his concurring  
               opinion in the California Supreme Court case, Lane v.  
               Hughes Aircraft 22 Cal.4th 405, 418, "large and  
               disproportionate punitive damage awards are not a  
               problem in our judicial system in any significant  
               degree - there is not punitive damages crisis."   
               (Citing Rustad, Unraveling Punitive Damages: Current  
               Data and Further Inquiry (1998) Wis. L. Rev. 15,  
               54-55.)  Indeed, any risk that an award is "excessive"  
               is properly addressed in a motion for a new trial  
               pursuant to Code of Civil Procedure  657.

           Prior Pertinent Legislation  :  AB 1443 (Zettel) of 1999 would  
          have prohibited the award of punitive damages for harm caused by  








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                                                                  Page  14

          a drug or device approved or licensed by the FDA unless the  
          product manufacturer knowingly withheld or misrepresented  
          information or violated federal law with the intent to defraud  
          or mislead.  Status:  Died in the Assembly Judiciary Committee  
          without a hearing. 

          AB 169 (Ackerman) of 1999, would have strictly limited punitive  
          damages to three times the amount of compensatory damages,  
          required that the amount of punitive damages be decided by  
          judges rather than juries, and imposed other restrictions on the  
          award of punitive damages in civil actions.  Status:  Failed  
          passage in the Assembly Judiciary Committee.
           
          AB 1371 (Morrow) of 1998, would have required that the amount of  
          punitive damages be decided by judges rather than juries,  
          prohibited the defendant's financial condition from being  
          considered in determining the amount of the damages award, and  
          required that the amount of damages be reduced by the extent to  
          which it would unfairly duplicate other punitive damages awards  
          paid for the same conduct.  Status:  Failed passage in the  
          Assembly Judiciary Committee.

          AB 1862 (Morrow) of 1995, which was identical to AB 169  
          (described above), failed passage in the Senate Judiciary  
          Committee.

          AB 2582 (Ackerman) of 2000, similar to AB 1443 (Zettel), would  
          have prohibited the award of punitive damages for harm caused by  
          a drug or device approved or licensed by the FDA unless the  
          product manufacturer knowingly withheld or misrepresented  
          information or violated federal law with the intent to defraud  
          or mislead.  Status:  Failed passage in the Assembly Judiciary  
          Committee.  
           
           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          Civil Justice Association of California (CJAC) (sponsor)
          Association of California Insurance Companies
          Association of California Life & Health Insurance Companies
          California Chamber of Commerce
          California Medical Association
          Consulting Engineers and Land Surveyors of California
          Personal Insurance Federation of California








                                                                  AB 840
                                                                  Page  15

          South Orange County Regional Chambers of Commerce

           Opposition 
           
          California Conference Board of the Amalgamated Transit Union
          California Conference of Machinists
          California Labor Federation, AFL-CIO
          Congress of California Seniors
          Consumer Attorneys of California
          Consumers for Auto Reliability and Safety
          Engineers and Scientists of California
          Foundation for Taxpayer and Consumer Rights
          Hotel Employees, Restaurant Employees International Union
          Region 8 States Council of the United Food & Commercial Workers  


          Analysis Prepared by  :    Drew Liebert / JUD. / (916) 319-2334