California, United States of America
The following excerpt is from Kenne v. Stennis, B221752 (Cal. App. 2013):
or quasi-fiduciary duties, as in bad faith refusal to pay insurance proceeds. [Citations.]" (Branch v. Homefed Bank (1992) 6 Cal.App.4th 793, 800.) Thus, there is no impropriety in an award of noneconomic damages for breach of fiduciary duty.
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