Supreme Court of Maryland

Arthur J. Hoffman v. Toyome Stamper

February 4, 2005385 Md. 1

Summary

The court affirmed the compensatory-liability judgments and the limited punitive-damages retrial, but reversed the awards of non-economic damages for most plaintiffs and the remand concerning attorneys’ fees. It held that the evidence supported findings that Hoffman knowingly participated in the fraudulent scheme and that his appraisals infected the consumer sales, while damages amounts could be proved by a preponderance of the evidence. The court also held that emotional damages in fraud actions require an objectively ascertainable physical manifestation, except that Haley could pursue a properly instructed retrial on that issue.