That's an unusual term for it, but all other jurisdictions require some heightened level of fault to support punitives.
Most jurisdictions look for recklessness or some similarly egregious failure to take care.
As in Livigni, however, the facts that support a finding of negligence often will suffice to meet the higher fault standard as well. In particular, courts seem more than willing to allow punitives when high-risk employers fail to take needed precautions in screening employees or responding to notice of dangerous propensities. I hope that is helpful.