Texas Supreme Court
Bellefonte Underwriters Insurance Company, Petitioners v. Leon Brown, Respondents
February 19, 198629 Tex. Sup. Ct. J. 227
Summary
The Texas Supreme Court reversed the award of punitive damages because no actual damages in tort were found. The Court held that punitive damages cannot be awarded for breach of contract absent an independent tort with actual damages, and it reversed the appellate court's implication of such damages.