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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Bernstein v. Fernandez, 649 A.2d 1064 (1991)

Citation
Bernstein v. Fernandez, 649 A.2d 1064 (1991)
Parent Document
Bernstein v. Fernandez, 649 A.2d 1064 (1991)
Jurisdiction
DC (municipal)
Effective Date
1991-03-28

Other Sections in This Document (123)

Full Text

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First, because the nuisance claim should have been resolved in H & M’s favor, compensatory damages were not available on that claim. An award of punitive damages cannot stand alone, unaccompanied by compensatory damages. Zanville v. Garza, 561 A.2d 1000, 1001-1002 (D.C.1989) (citing cases). We must therefore reverse the award of punitive damages on the nuisance claim.