California, United States of America
The following excerpt is from Davies v. Krasna, 111 Cal.Rptr. 18, 35 Cal.App.3d 662 (Cal. App. 1973):
The fact that appellant also asks for exemplary damages is immaterial, as such damages are obtainable in an equitable action to establish a constructive trust. (Rivero v. Thomas, 86 Cal.App.2d 225, 239, 194 P.2d 533.)
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