Supreme Court of Connecticut
McCarter & English, LLP v. Jarrow Formulas, Inc.
February 4, 2025351 Conn. 186
Summary
The court answered a certified question by holding that a law firm cannot recover common-law punitive damages for a client's breach of a fee agreement unless it pleads and proves an independent tort supporting punitive damages. The court adopted the majority rule because contract damages are compensatory, whereas punitive damages serve punishment and deterrence, and rejected a broader rule based solely on wilful, malicious, or reckless breach. The court preserved existing insurance and surety exceptions but left any additional exceptions for another case.