California, United States of America
The following excerpt is from Brown v. Zive, B250561 (Cal. App. 2015):
complaint stated a cause of action for punitive damages with respect to her claim for breach of fiduciary duty, and section 3294, subdivision (a) allows for the recovery of punitive damages as to that cause of action, if appropriate. (Scott v. Phoenix Schools, Inc. (2009) 175 Cal.App.4th 702, 715.)
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