Nash v. Craigco, Inc.

I respectfully dissent.

Though there may have been a question for the jury on the issue of malice, it is my opinion that plaintiff was not prejudiced by the Court’s ruling. Punitive damages are improper in this case. Plaintiff prayed for specific performance of the option agreement and conveyance of his 501 shares. He has not pled nor proved any actual or com-pensable damages.

This Court has consistently held that punitive damages must bear a reasonable relationship to actual damages suffered.1 Requiring as a prerequisite to an award of punitive damages that a party demonstrate the harm he has…