Dewey Dahl and Lavonne Dahl, Plaintiffs and Appellants v. Peter Sittner and Sittner Real Estate, Inc., Defendants…

Summary

The court held that the statutory threshold for punitive-damages claims applies to fraud and deceit claims and applies to actions pending when the statute took effect because it is procedural. It adopted the complicity rule for determining when a principal may be liable for punitive damages based on an agent's conduct, but held that the evidence created genuine factual issues concerning the principal's possible recklessness and complicity. The court therefore affirmed in part, reversed in part, and remanded for jury consideration.