Rite Aid Corp. v. Lake Shore Investors
Maryland Court of Appeals
471 A.2d 735 (1984)
Lake Shore Investors (plaintiff) agreed to sell property to BTR Realty; Rite Aid Corporation (defendant) claimed it owned part of the property, prompting BTR to demand a written release from Rite Aid before closing. When Rite Aid refused to sign, BTR withdrew from the deal, and Lake Shore sued Rite Aid for falsely claiming a lease interest and for tortious interference with the Lake Shore-BTR contract. The trial judge measured damages under a strict 'benefit of the bargain' contract-law standard and then directed a verdict for Rite Aid; the court of special appeals reversed and ordered a new trial, and the Maryland Court of Appeals granted review.
Whether an award of punitive damages for tortious interference with a contract in Maryland first requires a finding of compensatory damages, even if only nominal.