In a personal injury action, how have the principles of bad faith been applied to a finding in favour of punitive damages?

Appellant argues Edmund failed to prove that he acted in bad faith when he was unable to comply with the probate court's disgorgement order because he did not have the personal assets to refund the money. In asserting error, he analogizes a finding of bad faith to a finding in favor of punitive damages, relying on Adams v. Murakami (1991) 54 Cal.3d 105. However, he cites no cases that have applied the principles of punitive damages law to penalties awarded under Probate Code section 859. We decline his invitation to apply Adams to this case. As he offers no other challenge to the probate court's ruling, we find no error.