In the Matter of the Estate of Madeleine L. Stockdale, Deceased

Summary

The Supreme Court of New Jersey clarified the limited circumstances under which punitive damages may be awarded in Probate Part actions based on undue influence. It held that the Appellate Division’s award of attorneys' fees was not a proper substitute for punitive damages and affirmed the judgment as modified, remanding for further consideration of a punitive award. The Court also rejected the argument that the law‑of‑the‑case doctrine barred such an award.