§663-1.2 Tort liability for breach of contract; punitive damages. No person may recover damages, including punitive damages, in tort for a breach of a contract in the absence of conduct that:
(1) Violated a duty that is independently recognized by principles of tort law; and
(2) Transcended the breach of the contract. [L 1999, c 237, §1]
Law Journals and Reviews
Russ Francis v. Lee Enterprises: Hawaii Turns Away From Tortious Breach of Contract. 23 UH L. Rev. 647 (2001).
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