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3833 REVIEW DENIED In an action brought by members of a partnership for breach of fiduciary duty by a managing partner, a relatively low amount of compensatory damages caused by the defendant's egregiously reprehensible conduct may justify a punitive damages award ($1.5 million) greater than nine times compensatory damages ($165,000); in determining the ratio of punitive to compensatory damages, the compensatory damages amount should include prejudgment interest but not litigation costs and attorney fees.CitationBARDIS v OATES (Crooked Partner) 119 CA4 1 [See: Cooper v Leatherman 532 US 424; BMW v Gore 517 US 559; State Farm v Campbell 538 US 408, T/AT 7/03]
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