Lara v. Cadag

Opinion

VOGEL (Miriam A.), J.

The question before us is whether a plaintiff in pursuit of an award of punitive damages can satisfy her obligation to present evidence of the defendant’s financial condition without some proof of his net worth or something akin to “net worth.” We hold that where, as here, the evidence is limited to proof of the defendant’s annual income, there is insufficient evidence to support an award of punitive damages.

Facts

Plaintiff Ana Lara sued defendant Santiago Cadag for damages, asserting the usual assortment of intentional tort theories and alleging that Cadag had…