Chavez v. Keat

In Chavez v. Keat (1995) 34 Cal.App.4th 1406, the plaintiffs brought a federal civil rights action in state court and were awarded compensatory and punitive damages. On appeal, the defendant argued the plaintiffs were not entitled to punitive damages because, among other things, they failed to present evidence of the defendant's financial condition, as required by state law. ( Id. at p. 1411.) The court rejected the defendant's argument, concluding federal law, which does not require such a showing, is controlling. The court explained: "'Practice and procedure' refers to 'the mode of proceeding by which a legal right is enforced, as distinguished from the substantive law which gives or declares the right . . . .'" ( Chavez v. Keat, supra, 34 Cal.App.4th at p. 1414.) The court concluded a rule requiring the plaintiff to introduce evidence of financial condition in order to recover punitive damages is substantive in nature and therefore governed by federal law. ( Id. at p. 1416.)