must satisfy each fac by VECO, Inc. v. Rosebrock, 970 P.2d 906, 924 n. 36 (Alaska 1999) (disapproving of possible broad interpretation and requiring employee's act to have at least some motivation to serve corporation}. 16 . Alaskan Village, Inc. v. Smalley, 720 P.2d 945, 948 (Alaska 1986). 17 . Norcon, Inc. v. Kotowski, 971 P.2d 158, 175 (Alaska 1999). 18 . 720 P.2d at 948-49. 19 . Goddard v. Grand Trunk Rwy., 57 Me. 202, 222-23 (1869), as quoted in Embrey v. Holly, 293 Md. 128, 442 A.2d 966, 970 (1982) (quoting this language as justification for following the course of employment approach); see also Miller v. Blanton, 213 Ark. 246, 210 S.W.2d 293, 297 (1948) ("Having, by the constitution of their being, to act solely by ston & Strawn, 184 Ariz. 120, 907 P.2d 506, 521 (App. 1995) (<HOLDING>). 22 . See Alaska Evidence Rule 103(a)(1); see
holding that punitive damages award against vicariously liable law firm was not excessive in part because the award is proportionate to the law firms financial position holding a court may not award punitive damages holding that it was appropriate for trial court to award separate punitive damages awards against an employee and his vicariously liable employer because this would enable each award to be based on the two defendants differing financial status holding that evidence of a defendants financial condition is a prerequisite to an award of punitive damages recognizing the financial position of the defendant as a factor in assessing a punitive damages award