In Castro v. County of Los Angeles, 785 F.3d 336 (9th Cir. 2015), the Ninth Circuit held that the deliberate-indifference standard for constitutional violations and the reckless-indifference standard for punitive damages in § 1983 cases are synonymous. Thus, juries “have the discretion to impose punitive damages if they believe further punishment above and beyond compensatory damages is appropriate, without having to make any additional factual findings.”