1. Whether the Due Process Clause requires California appellate courts to review punitive damages awards de novo, as this Court held in Cooper Industries, Inc. v. Leatherman Tool Group, Inc., 532 U.S. 424 (2001), or permits review under a deferential "substantial evidence" standard.

2. Whether the Due Process Clause is violated when a court upholds a punitive damages award based solely on statutory "malice" in a case involving purely economic harm, where the award is disproportionate to both the reduced compensatory award and comparable statutory penalties.

Whether the Due Process Clause requires California appellate courts to review punitive damages awards de novo or permits review under a deferential 'substantial evidence' standard, and whether the Due Process Clause is violated when a court upholds a punitive damages award based solely on statutory 'malice' in a case involving purely economic harm