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Follo v. Florindo
Supreme Court of Vermont (2009) | 2009 VT 11; 970 A.2d 1230; 185 Vt. 390; 2009 Vt. LEXIS 3
TL;DR: Sellers of a bed and breakfast misrepresented its revenues to a buyer. The court upheld the fraud verdict and clarified that a finding of actual fraud inherently contains the malice required to allow a jury to consider punitive damages.
Legal Significance: This case establishes that a finding of actual common-law fraud is, by itself, a sufficient basis to submit the issue of punitive damages to a jury, as the requisite malice is inherent in the tort itself.