On what basis may an appellate court overturn a jury's award of punitive damages?
a) When it is shown by clear and convincing evidence that the amount of the award would severely hurt the defendant.
b) If the appellate court thinks the amount is so high that it "shocks the judicial conscience."
c) If it is shown by a preponderance of the evidence that the plaintiff did not suffer an "actionable" injury.
d) Under no circumstances may an appellate court overturn a jury's award of punitive damages.