future conduct of that nature. Punitive damages are generally limited
to cases in which a defendant's behavior has been especially egregious
or reckless. Punitive damages are seldom available in contract actions
but may be received for negligence or, especially, for fraud. Punitive
damages today are far more common and far larger in amount than
they were even a decade ago. Courts and commentators are increas-
ingly critical of the trend to granting punitive damages, and various
devices are being adopted to restrain such awards. For example, some
courts require a comparability between actual damages and punitive
damages and reject verdicts where punitive damages far exceed com-
pensatory actual damages. Notwithstanding these efforts, punitive
damages are granted fairly often in cases in which a defendant has
endangered a plaintiff's health, and these damages can materially
increase such a plaintiff's recovery in indoor air litigation.

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