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4522 In a bad faith action against an insurer based on its refusal to defend, an award that fully compensated plaintiff for all economic damages and attorney fees and included substantial damages for emotional distress was found to include a punitive element; this, coupled with the relatively minor reprehensibility of the insurer's conduct, justified reduction of punitive damages to result in a one-to-one ratio of punitive to compensatory damages.CitationWALKER v FARMERS (HOA Insurer) 153 CA4 965 [See: State Farm v Campbell 538 US 408, T/AT 7/03; Simon v San Paolo 35 C4 1159, T/AT 7/05]
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