White v. Benkowski

The Whites (plaintiffs) contracted with their neighbors the Benkowskis (defendants) to pay for water access from the Benkowskis' well; after the relationship soured, the Benkowskis repeatedly shut off the water for short periods, inconveniencing but not causing pecuniary loss to the Whites. The jury, instructed that only nominal damages were available absent proof of pecuniary loss, nonetheless awarded $10 in compensatory and $2,000 in punitive damages after finding malicious breach; the trial court reduced this to $1 compensatory and no punitive damages, and the Whites appealed.

Whether punitive damages may be awarded on a claim for breach of contract.