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3811 REVIEW DENIED Punitive damages in an action for breach of an insurance contract and bad faith should be compared with compensatory damages in the bad faith action only and should not exceed four times that award if plaintiff's harm is solely economic, plaintiff is not a financially vulnerable person, and plaintiff's loss is fully compensated by the damages award; in a bad faith action resulting in a compensatory damages award of $90,000, punitive damages of $1.7 million were excessive and are properly reduced to $360,000, which is four times the compensatory damages.
TEXTRON v NATIONAL UNION (Bad Faith Puni's) 118 CA4 1061 [See: CivC 3294; BMW v Gore 517 US 559; Cooper v Leatherman 532 US 424; State Farm v Campbell 538 US 408, T/AT 7/03]
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