In Dees v. Logan, 281 Ga. App. 837, 837-838 (1) (637 SE2d 424) (2006), rev'd on other grounds, 282 Ga. 815 (653 SE2d 735) (2007), the trial court granted a motion in limine to exclude evidence of the defendant driver's intoxication over the plaintiffs' objection that "such evidence was probative of their entitlement to punitive damages." Id. at 838 (1). The Court affirmed on the ground that none of the defendants could be held liable for punitive damages as a matter of law. Id. In doing so, the Court expressly declined to address whether such evidence would have been admissible on the alternative ground that it was relevant to the issue of proximate cause. Id. at 838 (1), n. 1.