[§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.