Adams v. Coates

RODOWSKY, Judge.

Following decision by the Court of Special Appeals in an unreported opinion, we issued the writ of certiorari in this case to consider the two following questions:

“May a circuit court grant punitive damages in [a] case of an equitable nature that was decided subsequent to the adoption of Maryland Rule 2-301, merging law and equity[;]” and

“[If] the equitable nature of the proceedings does not preclude the award of punitive damages, is it incumbent upon your petitioner to prove actual malice in a case involving an intentional breach of a fiduciary relationship between the…