Wedeman v. City Chevrolet Co.

We granted certiorari here to decide whether punitive damages may be recovered without proof of actual malice in an action for fraud. In City Chevrolet v. Wedeman, 30 Md. App. 637, 354 A. 2d 185 (1976), the Court of Special Appeals held that in this case they were not recoverable, since the fraud was a tort arising out of a contractual relationship. Accordingly, proof of actual malice was required but not met. In so holding, the court reversed a punitive damage award of $6,000 returned by a jury in the Superior Court of Baltimore City (Perrott, J.). We think the Court of Special Appeals erred.