California, United States of America
The following excerpt is from Rufo v. Simpson, 103 Cal.Rptr.2d 492, 86 Cal.App.4th 573 (Cal. App. 2001):
Punitive damages are not awardable to the heirs on their own cause of action for wrongful death. (Code Civ. Proc., 377.61; Garcia v. Superior Court, supra, 42 Cal.App.4th at pp. 186-187 & fn. 7.)
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