Forquer v. Pinal County
In Forquer v. Pinal County, 22 Ariz. App. 266, 526 P.2d 1064 (1974), a wrongful death action that involved a punitive damage issue, the court concluded that "acts of the wrongdoer occurring after the liability creating event are normally not material on the issue of punitive damages unless such acts constitute evidence as to either the manner in which the liability-creating event occurred or to the aggravation of the victim's injuries." 22 Ariz. App. at 269, 526 P.2d at 1067.
Unless the post-accident conduct "has a reasonable relationship either to the state of mind of the tortfeasor at the time of the event itself or to the injured parties' actual damages," the court stated, evidence of such conduct generally "is inadmissible on the issue of punitive damages." Id. at 270, 526 P.2d at 1068.