On Feb. 6, 2003, plaintiff’s decedent Betty Bullock, 64, died from cancer that had metastasized from her lungs. Bullock started smoking in 1956, at age 17. She allegedly smoked one to two packs of cigarettes per day for over 40 years. She smoked Marlboro cigarettes and then Benson & Hedges cigarettes, both of which are brands manufactured by Philip Morris USA Inc. However, in February 2001, Bullock, then 62, was diagnosed with small cell lung cancer, which later metastasized to her liver. In April 2001, Bullock filed suit against Philip Morris for negligence, strict liability, false representation, deceit and fraudulent concealment, civil conspiracy, breach of express warranty, unfair competition/unlawful business practices, negligent/intentional false and misleading advertising, and punitive damages. Bullock testified that she had attempted to quit smoking on numerous occasions, but was unsuccessful, despite knowing that smoking aggravated her bronchitis and pneumonia, and despite her doctors telling her to reduce her smoking or to stop her smoking over a period of more than 10 years. She also testified that she was aware of the Surgeon General warnings on cigarette packages and of public health organizations’ warnings that smoking could cause lung cancer. However, she said she believed the cigarette manufacturer’s statements that the cause of lung cancer was not known, that no real proof existed showing that smoking cigarettes caused lung cancer, and that further research was required. Plaintiff’s counsel during that trial contended that Philip Morris never tested its product for biologic activity for over 50 years; that it conducted a misinformation/disinformation campaign for over 45 years aimed at addicted smokers; that it fraudulently concealed the degree of danger of its product; that it failed to warn or instruct (prior to the 1969 pre-emption) that light cigarettes were as hazardous as full-strength cigarettes; and that it was able to manufacture an almost safe cigarette, but did not want to endanger Marlboro’s dominant market position by properly promoting ultra-low tar cigarettes. Philip Morris argued that there was no such thing as a safe cigarette. The cigarette manufacturer turned the spotlight on Bullock and her decision to smoke, arguing that the general public, including Bullock, had long known of the dangers of cigarettes and that it was her personal choice to smoke. The company said that Bullock’s testimony showed that she was aware of the health risks of smoking and was warned repeatedly of those risks by her doctors. The company also pointed out that had Bullock stopped smoking, even in the 1980s, she would not have lung cancer. On Oct. 4, 2002, a Los Angeles County Superior Court jury found Philip Morris liable for fraud and negligence, and it awarded Bullock $850,000 in compensatory damages and $28 billion in punitive damages. However, the trial court reduced the punitive damages award to $28 million, and both parties appealed. Betty Bullock died on Feb. 6, 2003, and Jodie Bullock continued to litigate the case on behalf of her mother’s estate. On Jan. 30, 2008, the California Court of Appeal remanded the case to the Los Angeles County Superior Court for a retrial of the punitive damages phase. On Aug. 24, 2009, following the retrial, the jury awarded Jodie Bullock, who was continuing the suit as a representative of her mother’s estate, $13.8 million in punitive damages. The Court of Appeal later affirmed that verdict on Aug. 17, 2011, and judgment has been paid in full. Jodie Bullock then filed a separate, civil wrongful death action against Philip Morris USA Inc., seeking noneconomic damages for the loss of love, companionship, comfort, care, assistance, protection, affection, society, moral support, training, and guidance that her mother would have provided to her if not for Betty Bullock’s death. Jodie Bullock filed the instant lawsuit against Philip Morris in the Los Angeles County Superior Court on Feb. 11, 2014, but the matter was removed to the federal district court by Philip Morris. Jodie Bullock claimed that her mother’s death was attributed to lung cancer, which Betty Bullock incurred as a result of smoking cigarettes produced by Philip Morris. On Oct, 15, 2014, the federal court ruled that Philip Morris was estopped from contesting liability for Betty Bullock’s death. Thus, the matter proceeded to trial with the issues limited to whether Jodie Bullock would be entitled to noneconomic damages resulting from Betty Bullock’s death, and to what extent. The jury was not informed of the amounts of any of the previous recoveries achieved by Betty Bullock’s estate or by Jodie Bullock derivatively., Betty Bullock developed terminal lung cancer and subsequently underwent chemotherapy and radiation therapy, but they failed to eradicate the cancer. Instead, it metastasized to her liver and she died on Feb. 6, 2003. Betty Bullock was 64. The decedent’s daughter, Jodie Bullock, claimed that there was unusually strong bond between her mother and herself. At trial, she proffered witness testimony, photographs, cards, and videos in an attempt to bolster that contention. Thus, Jodie Bullock sought recovery of noneconomic damages for the loss of her mother’s love, companionship, comfort, care, assistance, protection, affection, society, moral support, training, and guidance. In view of the court’s ruling that the trial would be limited to damages only, defense counsel was limited to testing and challenging the veracity and competence of the evidence that plaintiff’s counsel presented in support of Jodie Bullock’s claim for noneconomic damages as permitted by California’s wrongful death statute.