University of Baltimore Law Review


The author discusses the Maryland law governing the recovery of punitive damages in tort actions. Centering on the recent court of appeals decisions in H & R Block, Inc. v. Testerman and Wedeman v. City Chevrolet Co., the author analyzes the distinction between actions for torts arising out of contracts and pure actions for torts, and concludes that the standards articulated in Testerman and Wedeman are those applicable to all punitive damages awards in Maryland cases.

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