Ellerin v. Fairfax Savings

Opinion by ELDRIDGE, Judge.

This case concerns the appropriate standard for the availability of punitive damages in a tort action of fraud or deceit.

I

The litigation arose from commercial real estate development loans. In 1982, Charles Ellerin and Louis Seidel decided to acquire four historic buildings in Westminster, Maryland, for commercial development. Ellerin and Seidel planned to *220develop the properties through a limited partnership, Sherwood Square Associates (“Sherwood”), of which they were the general partners.

Ellerin and Seidel financed their project through Fairfax Savings, F.S.B.…