What must I prove to receive punitive damages?

The evidence must support more than a mistake or failure to use reasonable care. The plaintiff generally needs facts showing that the defendant appreciated a serious risk and consciously disregarded it, or acted with an improper motive so extreme that punishment is warranted. Internal records, prior warnings, training materials, electronic data, testimony, and repeated safety violations may become important.
A punitive-damages request also depends on proving an underlying claim and meeting the procedural and substantive rules that apply to the defendant and cause of action. Because the standard is demanding, counsel should investigate before alleging punitive conduct and avoid treating it as a routine addition to every complaint.