Filed 3/18/21 CERTIFIED FOR PUBLICATION COURT OF APPEAL, FOURTH APPELLATE DISTRICT DIVISION ONE STATE OF CALIFORNIA ROSARIO CONTRERAS-VELAZQUEZ, D075577 Plaintiff and Appellant, v. (Super. Ct. No. 37-2014- 00026469-CU-WT-CTL) FAMILY HEALTH CENTERS OF SAN DIEGO, INC., Defendant and Appellant. APPEALS from a judgment and a postjudgment order of the Superior Court of San Diego County, Jeffrey B. Barton, Judge. Affirmed. Mulvaney Barry Beatty Linn & Mayers, John A. Mayers, Patrick L. Prindle; Law Offices of Mary A. Lehman and Mary A. Lehman, for Defendant and Appellant. Law Office of Martin N. Buchanan, Martin N. Buchanan; Hogue & Belong, Jeffrey L. Hogue and Tyler Belong, for Plaintiff and Appellant. I INTRODUCTION Rosario Contreras-Velazquez (Velazquez) sued her former employer, Family Health Centers of San Diego, Inc. (Family Health), alleging disability discrimination and related causes of action after she suffered a work-related injury and Family Health terminated her employment. A jury found Family Health not liable, but the trial court ordered a new trial as to three of Velazquez’s causes of action after finding the evidence was insufficient to support the jury’s verdict—a ruling we affirmed in a prior appeal. (Contreras-Velazquez v. Family Health Centers of San Diego, Inc. (Aug. 9, 2017, D071083) [nonpub. opn.] (hereafter, Velazquez I).) At the ensuing retrial, a jury found in favor of Velazquez. The jury awarded her $915,645 in compensatory damages and $5 million in punitive damages. However, the trial court granted in part a motion for judgment notwithstanding the verdict (JNOV) and reduced the punitive damages award to $1,831,290 (a 2:1 ratio of punitive to compensatory damages). The court reasoned a punitive damages award equal to twice the compensatory damages award was the maximum amount permissible under the due process clause of the Fourteenth Amendment to the United States Constitution. Family Health appeals the judgment and contends certain special verdict findings returned by the first jury estopped Velazquez from prevailing at the retrial under the issue preclusion doctrine. Family Health also appeals the JNOV order on the basis that the reduced punitive damages award remains grossly excessive in violation of Family Health’s due process rights. Family Health requests the punitive damages award be further reduced to $915,645 (a 1:1 ratio of punitive to compensatory damages). Velazquez cross-appeals the JNOV order and requests reinstatement of the $5 million punitive damages award. We conclude the first jury’s special verdict findings did not constitute a final adjudication of any issue and, therefore, the trial court correctly ruled that the issue preclusion doctrine did not require entry of judgment in Family 2 Health’s favor. Further, we conclude the trial court properly reduced the punitive damages award to an amount equal to twice the compensatory damages award—and no further. Therefore, we affirm both the judgment and the JNOV order. II BACKGROUND A Velazquez’s Termination From 2003 to 2006, Velazquez worked as a medical records clerk and a patient service representative for Family Health, a non-profit organization that operates community health clinics. She stopped working for Family Health in 2006, but was rehired …
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