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1399 REVIEW DENIED A jury may be informed of prior punitive damages awards against the defendant for the conduct at issue in a particular case so that it can determine whether further punishment is necessary, but an appellate court should not consider such prior awards unless evidence of them was presented to the jury.
STEVENS v OWENS-CORNING (Prior Puni's) 49 CA4 1645 [See: Pacific Mutual v Haslip 499 US 1; BMW v Gore 116 SCt 1589; Cummings v Occupational 10 CA4 1291, T/AT 1/93; Kenly v Ukegawa 16 CA4 49, T/AT 8/93; Adams v Murakami 54 C3 105; Neal v Farmers 21 C3 910; Vossler v Richards 143 CA3 952; Gagnon v Continental 211 CA3 1598]
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