Can You Seek Punitive Damages for a Breach of Contract in Florida?

In Florida personal injury cases, a judge or jury can award punitive damages in exceptional cases where there is “clear and convincing evidence” that the defendant committed intentional misconduct or gross negligence. Put differently, punitive damages are meant to punish especially reprehensible behavior that goes above and beyond ordinary negligence. That is why such damages exist separately from compensatory damages, which are meant to compensate the plaintiff for the losses they sustained as a result of the defendant’s actions.

Third District Quashes Personal Injury Damages in Aircraft Maintenance Dispute

In general, punitive damages are not an option in Florida cases involving a breach of contract. Punitive damages are a function of tort (personal injury) law. This means that unless the breach of contract claim is accompanied by a separate and independent tort claim, a judge or jury cannot award punitive damages for a breach of contract alone.

A recent decision from the Florida Third District Court of Appeal, Boca Aircraft Maintenance, LLC v. Fifteen Capital Group Capital, LLC, helps to illustrate this point. In this case, the plaintiff leased several aircraft that required periodic inspection and maintenance. The plaintiff hired a third-party company to manage its aircraft, and this third-party in turn vetted the defendant as a maintenance contractor. The plaintiff and the defendant subsequently signed a maintenance contract.

Several months later, one of the aircraft serviced by the defendant was involved in a minor incident while in service. The aircraft’s pilot attempted to retract the airplane’s flaps upon landing but the retraction system malfunctioned. The problem was corrected on the ground, but had the malfunction occurred during the flight, there could have been a catastrophic accident.

The plaintiff subsequently sued the defendant alleging breach of contract and negligence, among other things. The plaintiff also sought punitive damages. Following a bench trial, a Florida judge ruled in favor of the plaintiff. The court found that the defendant was negligent in failing to follow FAA regulations when performing its maintenance work on the aircraft. Additionally, the judge found the defendant’s employees “made fraudulent misrepresentations” and thereby committed “gross negligence” when they falsely told the plaintiff’s representative that they had mechanics trained on the plaintiff’s specific aircraft.

The court awarded about $180,000 in damages for the breach of contract, another $92,000 in tort damages, and $1.5 million in punitive damages. The Third District subsequently held, however, that neither the tort nor punitive damages were permitted under Florida law, because the defendant’s fraud and negligence were simply part of the breach of contract claim. The trial court had “arbitrarily assigned” some of the breach of contract damages to tort damages, the Third District said. And punitive damages were not available for a breach of contract claim.

Contact a Bradenton Business Litigation Lawyer

Contractual disputes often arise when a business relationship goes bad. If you need legal advice or representation in such a matter, our Bradenton business litigation attorneys are here to help. Contact Suncoast Civil Law today at 941-366-1800 to schedule a confidential case evaluation.

Source:

scholar.google.com/scholar_case?case=2719656427348730291