In Cloud v. Casey (1999) 76 Cal.App.4th 895, a female employee was passed over for promotion because of her gender. The court held the employer was liable for punitive damages because it denied the plaintiff a promotion based on gender, then attempted to hide the illegal reason for denying the promotion with a false explanation, and that it was this fabrication that constituted the despicable conduct. (Id. at p. 912.) In Cloud v. Casey, the trial court granted judgment notwithstanding the verdict, overturning the jury's finding that the plaintiff's employer acted with malice and oppression when it discriminated against her because of her gender. (76 Cal.App.4th at pp. 900, 911.) The Court of Appeal reversed, holding there was substantial evidence to support a determination that the employer intentionally discriminated against the plaintiff by refusing to promote her because of her gender, then claimed it did not promote her because she lacked experience. (Id. at pp. 911-912.) It reasoned the jury could properly conclude that by intentionally discriminating, then attempting to hide the illegal reason for its decision with a false explanation, the employer acted in a base, vile, or contemptible manner. (Id. at p. 912.) Evidence that the employer attempted to hide the improper basis with a false explanation also supported a determination the conduct was willful and in conscious disregard of the plaintiff's rights. (Ibid.)