[§663-1.2]  Tort liability for breach of
contract; punitive damages.  No person may recover damages, including
punitive damages, in tort for a breach of a contract in the absence of conduct
that:



(1)  Violated a duty that is independently recognized
by principles of tort law; and



(2)  Transcended the breach of the contract. [L 1999,
c 237, §1]



 



Law Journals and Reviews



 



  Russ Francis v. Lee Enterprises:  Hawai‘i Turns Away From
Tortious Breach of Contract.  23 UH L. Rev. 647.