LOS ANGELES - While agreeing that a remitted bad faith punitive damages award against an insurer may not serve as much of a deterrent, a California appeals panel majority on Aug. 29 affirmed the $350,000 award, which had been reduced from $19 million, stating that it was "constrained by case law and the Constitution" (Thomas Nickerson v. Stonebridge Life Insurance Co., No. B234271, Calif. App., 2nd Dist.; 2013 Cal. App. LEXIS 693).