Tort liability for breach of contract; punitive damages
Applied in 4 court decisions — leading case BlueEarth Biofuels, LLC v. Hawaiian Electric Co. (2011)
Most recently applied in Maeda v. Pinnacle Foods Inc. (May 2019)
L 1999, c 237, §1
Court decisions citing this, by year. The dip in the last several years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the most recent years, so recent citations are undercounted.
No person may recover damages, including punitive damages, in tort for a breach of a contract in the absence of conduct that:
(1) Violated a duty that is independently recognized by principles of tort law; and
(2) Transcended the breach of the contract.
Official source: Hawaii State Legislature. Reproduced from public-domain Hawaii statutes; confirm against the official source for the current text. Not legal advice.