The Arizona Court of Appeals held that on the evidence before it a jury was entitled to determine whether the Adult Protective Services Act (APSA) plaintiff in that case should be awarded punitive damages. Plaintiff had presented evidence that he had suffered a significant pressure ulcer and that although defendant’s nurses knew the course of treatment required for his pressure sore they failed to uphold those treatment standards, thereby disregarding a known risk of substantial harm. The court therefore remanded for a new trial on punitive damages.