Tort liability for breach of contract; punitive damages.
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HI Code › Division 4 › Title 36 › Chapter 663 › Section 663-1.2
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No person may recover damages, including punitive damages, in tort for a breach of a contract in the absence of conduct that:
(1) Violated a duty that is independently recognized by principles of tort law; and
(2) Transcended the breach of the contract. [L 1999, c 237, §1]
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