Beverly Hills, CaliforniaMonday–Friday · 10am–5pm
California State Bar #81160 · Active323-655-0961

Home/ Appellate Record/ Adams v. Murakami

California Supreme Court · 1991

Adams v. Murakami

California Supreme Court decision addressing the evidentiary prerequisite for punitive damages and the burden of proof.

Case Brief

Background, issue and holding.

Background

Adams v. Murakami was a California Supreme Court case arising from a personal-injury action in which the jury awarded compensatory and punitive damages. No evidence of the defendant physician’s financial condition had been introduced at trial, even though the punitive-damages instruction directed the jury to consider financial condition.

The questions before the court

The Supreme Court addressed two related questions: whether meaningful evidence of a defendant’s financial condition is a prerequisite to sustaining a punitive-damages award, and, if it is, which party bears the burden of introducing that evidence.

The court’s holding

The court answered both questions in the affirmative from the plaintiff’s perspective: meaningful evidence of the defendant’s financial condition is required, and the plaintiff bears the burden of producing it. The court reasoned that financial-condition evidence is necessary for meaningful review of whether punitive damages are excessive and for determining whether the award serves punishment and deterrence without becoming financially destructive.

Philip Kaufler’s role

The published opinion lists Philip Kaufler among counsel for the plaintiff/respondent. The linked public opinion contains the court’s complete analysis and separate opinions.

Consultation

Discuss an appellate matter.

Contact The Law Offices of Philip Kaufler in Beverly Hills.

Request Consultation