Jabro v. Superior Court
California Court of Appeal
115 Cal. Rptr. 2d 843 (2002)
Relevant factsFree
Hill (plaintiff) sued Matti and Jabro (defendants), claiming Matti beat him while shouting racial slurs outside Jabro's convenience store and that Jabro encouraged the attack. Hill sought punitive damages and moved to discover the defendants' financial condition to help value that claim. Believing Hill only needed a prima facie showing, the trial court looked only at Hill's evidence, found a prima facie punitive-damages claim, and granted discovery. Matti and Jabro appealed.
IssueFree
Whether a plaintiff must show a substantial probability of prevailing on a punitive-damages claim, based on evidence from both sides, before obtaining discovery of a defendant's financial condition.