While it is plaintiff’s burden to prove defendant’s wealth in order to recover punitive damages, the defendant’s noncompliance with a court order to disclose financial condition precludes a defendant from challenging the sufficiency of the evidence of a punitive damages award on appeal.  In this action by a former tenant against her former landlord for breach of the warranty of habitability and for retaliatory eviction, the trial court properly found the landlord liable for punitive damages and found the facts showed a sufficiently high degree of reprehensibility to justify a 4 to 1 ratio of punitive damages to compensatory damages.

California Court of Appeal, Third District (Duarte, J.); October 5, 2017 (modified November 2, 2017); 2017 WL 5076415.