Escamilla

INTRODUCTION

Veronica Escamilla appeals from a judgment in favor of Ace Atlantic Corporation and P&B Atlantic, LLC on her cross-complaints and in favor of Ace on its cross- complaint. She claims that there is insufficient evidence to support the compensatory damages award against her, and that the punitive damages award against her is unauthorized, violates her due process rights, and is excessive. We agree with her first contention and reverse the judgment as to Ace‟s cross-complaint. In all other respects, we affirm.

FACTUAL AND PROCEDURAL BACKGROUND

A. The Lease and Sublease Veronica Escamilla owns property located at 10862 Atlantic Avenue in Lynwood, California. On September 22, 1997 Escamilla leased the property to GCM Hand Carwashing, Inc. pursuant to a commercial lease (Master Lease). GCM operated a carwash on the property. Paragraph 11 of the Master Lease provided: “Tenant at its cost shall maintain during the term of this Lease on the Premises a policy . . . of standard fire and extended coverage insurance to the extent of at least ninety (90%) percent of full replacement value thereof. Said insurance policies shall be issued in the names of Landlord and tenant, as…