Pac. Gas & Elec. Co. v. Superior Court of Sacramento Cnty.

*1153 This coordinated proceeding arises out of the Butte Fire, a devastating wildfire that swept through Calaveras and Amador counties in September 2015. The fire started when a tree came into contact with an overhead power line owned and operated by petitioners Pacific Gas and Electric Company and PG&E Corporation (together, PG&E or the company). Real parties in interest (plaintiffs) brought suit against PG&E, seeking punitive damages under Public Utilities Code section 2106 and *1154 Civil Code section 3294. 1 PG&E sought summary adjudication of plaintiffs' request for punitive damages under section 3294 only. The trial court denied the motion.

PG&E seeks writ relief from the trial court's order. We conclude there are no triable issues of fact which, if resolved in plaintiffs' favor, could subject PG&E to punitive damages under section 3294. 2 Accordingly, we grant the petition.

I. BACKGROUND

A. The Butte Fire

The Butte Fire started on September 9, 2015, near Butte Mountain Road in Jackson, *232 California. 3 The fire spread rapidly through drought-stricken Amador and Calaveras counties. By the time the blaze was contained some three weeks later, the fire had consumed more…