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Doe v. Lee CA3
Appellant Andrew Kam Lee argues that a punitive damages award equal to the value of his alleged interest in real property held by an LLC of which he was once a member is excessive under California law and not supported by substantial evidence of his ability to pay the punitive damages award. The six Doe respondents failed to introduce any other evidence regarding appellant’s capacity to pay punitive damages, and we agree that this award is excessive given the evidence.
Appellant also argues the trial court abused its discretion in denying his request for a new trial on the punitive damages issue. Because we vacate the punitive damages award as excessive and not supported by substantial evidence, we need not consider this issue.

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