On Monday, September 9, 2019, the United States Court of Appeals for the Ninth Circuit affirmed the compensatory damages award of $5.25 million in litigation stemming from author John Steinbeck's estate, brought by Steinbeck's stepdaughter, Waverly Scott Kaffaga. In its ruling, the Ninth Circuit vacated the $7.9 million punitive damage award against Steinbeck's daughter-in-law, Gail Knight Steinbeck.