7.8.1 Punitive Damages.
| Jurisdiction | Arizona |
7.8.1 Punitive Damages.
Following Gertz , the Arizona Supreme Court has held that public figure plaintiffs and plaintiffs in cases touching on issues of public concern must demonstrate actual malice by clear and convincing evidence to recover punitive damages.61 By contrast, private figure plaintiffs suing over issues of private concern may recover punitive damages upon a showing of negligence.62
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Notes:
[61] Dombey, 150 Ariz. at 481, 724 P.2d at 567; Gertz, 418 U.S. at 349-50.
[62] Hirsch, 153...
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