McWilliams v. Hayes

Pope, Judge.

Appellant-landlord brought a dispossessory action against appellee-tenant for nonpayment of rent. Appellee counterclaimed for actual and exemplary damages based on the appellant’s failure to repair and maintain the premises in which she and her two small children resided. A jury trial resulted in a verdict awarding appellee $1,346 nominal damages and $5,000 punitive damages. Held:

1. Appellant first challenges appellee’s right to recover punitive damages, arguing, inter alia, that a mere breach of his contractual and statutory duty to repair would not authorize punitive damages.…