3722 REVIEW DENIED Under the United States Supreme Court's decision in State Farm v Campbell, punitive damages may not be used to punish a defendant's general course of reprehensible conduct, but only to punish the effect such conduct had on the individual plaintiff; because California law does not permit compensation for pain and suffering of decedents or the emotional distress of plaintiffs suing for wrongful death, compensatory damages awarded in such cases may be lower than actual harm sustained, justifying a punitive to compensatory damages ratio of five to one in a case involving highly reprehensible conduct.CitationROMO v FORD (Bronco Rollover) 113 CA4 738 [See: CivC 3294, 3295; Grimshaw v Ford 119 CA3 757; State Farm v Campbell 123 SCt 1513, T/AT 7/03; Romo v Ford 99 CA4 1115, T/AT 8/02; Ford v Romo 123 SCt 2072]
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