In another wrongful termination and defamation case, this decision follows Roby v. McKesson Corp. (2009) 47 Cal.4th 686, in holding that a one-to-one ratio of punitive damages to compensatory damages is the constitutional limit. Though emotional distress counts as physical injury for purposes of weighing reprehensibility, still plaintiff’s emotional distress was not as severe as Roby’s. Also, as in Roby, the wrongful conduct occurred in a single employment relationship with no evidence that the defendant’s wrongful conduct affected anyone but plaintiff or that it was part of any larger course of similar conduct in other cases.