(1) the degree of reprehensibility of the defendant’s misconduct; (2) the disparity between the actual or potential harm suffered by the plaintiff and the punitive damages award; and (3) the difference between the punitive damages awarded by the jury and the civil penalties authorized or imposed in comparable cases. Bains LLC v. Arco Prods. Co., 405 F.3d 764, 775 (9th Cir.2005) (citing BMW, 517 U.S. at 574-75, 116 S.Ct. 1589). Defendants’ Punitive Damages Motion fails to show that the punitive damage awards are unconstitutionally excessive. Defendants argue that the punitive damages awarded exceed Defendants’ ability to pay, and therefore the awards are excessive. This is not persuasive. Pac. Mut. Life Ins. Co. v. Haslip, 499 U.S. 1, 22, 111 S.Ct. 1032, 1045, 113 L.Ed.2d 1, 22 (1991) (<HOLDING>). In fact, Defendants’ ability to pay is a
holding that even if the trial court had erred in denying the defendants motion for a directed verdict on punitive damages the error was harmless because the jury found in favor of the defendant and never reached the punitive damages claims holding that conduct must be beyond the fraud which supported compensatory damages to award punitive damages holding what section 76872 requires is that a plaintiff who has pleaded punitive damages must offer a reasonable evidentiary basis for punitive damages and obtain an order authorizing the maintenance of the punitive damage claim as a predicate to conducting discovery of a defendants financial worth holding that in determining punitive damages the factfinder must be guided by more than the defendants net worth holding a court may not award punitive damages