Lawyers Title Ins. Corp. v. Vella

When can punitive damages be awarded in fraud actions? The lawyers for Lawyers Title Insurance Company correctly note:

"Intent to deceive is the bedrock of a fraud case. Without it, the law allows only compensatory damages. With it, punitive damages may be awarded at the jury's discretion. State Farm Fire Cas. Ins. Co. v. Lynn, 516 So.2d 1373, 1376 (Ala. 1987). To prove an intent to deceive, the [plaintiffs] were bound to produce evidence that [defendant] made a misrepresentation . . . knowing that it was false, or that [defendant's] conduct was so reckless that it amounted to the same thing…