Ramon International Insurance Brokers, Inc., etc., and Iris Arden v. Chaucer Syndicates Limited, etc., and Anova Marine Insurance Services, LLC
The Third District reversed a trial court's order permitting insurers Chaucer Syndicates and Anova Marine to amend their complaint to seek punitive damages on fraud counts, because the damages sought—premium differentials collected and wrongly retained—were identical to those sought under the parties' breach of contract claims. The court reaffirmed the established rule that pleading a fraud claim alongside a contract claim does not unlock punitive damages when the tort seeks no independent, non-duplicative recovery. The trial court's denial of the opposing parties' (Ramon International and Arden) motion to amend for punitive damages was affirmed without discussion.
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