Supreme Court allows court-awarded attorney’s fees to be included in punitive-damage calculus in insurance bad-faith cases

Nickerson v. Stonebridge Life Ins. Co. (2016) 63 Cal.4th 363
Held that Brandt fees awarded by trial court post-trial can properly be included in ratio of compensatory to punitive damages for purpose of federal due process review of punitive-damage award, reversing prior cases holding otherwise.