asserts, however, that a foundational showing must indicate the prior incidents occurred under substantially the same circumstances. Id. Nevertheless, we think Walgreen’s arguments lack merit. Shari was clearly trying to establish a pattern of conduct that showed that Walgreen knew of problems in getting prescriptions properly filled at the pharmacy on Ingersoll, yet did nothing to solve the problem. The challenged evidence was obviously relevant to the punitive-damage issue of willful and wanton conduct on the part of Walgreen. See Cook v. State, 431 N.W.2d 800, 803 (Iowa 1988) (“The probative value of previous accidents rests in the likelihood that the same conditions caused the accident under litigation.”); see also Harco Drugs, Inc. v. Holloway, 669 So.2d 878, 881 (Ala.1995) (<HOLDING>). It is true that Petersen was not named in all
holding that liquidated damages under userra are punitive and therefore subject to trial by jury holding that failure to warn plaintiff of error in filling her prescription was sufficient evidence of conscious indifference to plaintiffs rights to support an award for punitive damages holding that in order to submit a claim for punitive damages to a jury in a product liability action a plaintiff is required to produce evidence of actual knowledge holding that 233 incident reports prepared by defendants employees showing errors in filling prescriptions were relevant to show defendantpharmacists knowledge of problems within its pharmacies and therefore admissible on plaintiffs wantonness claim for punitive damages holding a court may not award punitive damages