In Michelson v. Hamada (1994) 29 Cal.App.4th 1566, the court reversed a punitive damage award of $ 1,250,000, which represented 28 percent of the defendant's net worth. (Id. at p. 1596.) In so doing, the court explained: "A court of review must intervene when the award is so disproportionate as to raise the presumption that it was the product of passion or prejudice, even though deference is due a trial court's approval of a punitive damage award. Punitive damages constitute a windfall. Such awards generally are not allowed to exceed 10 percent of the net worth of the defendant. We find the award to be excessive as a matter of law." (Michelson, supra, at p. 1596.)