Practice point: They are available only when defendant’s behavior evinces a high degree of moral turpitude, and is so wantonly dishonest as to imply a criminal indifference to civil obligations.
Students should note that they are not available in an action sounding in ordinary fraud and deceit.
Hoeffner v. Orrick, Herrington & Sutcliffe LLP , NY Slip Op 04760 (1st Dept. 2011 ).
Tomorrow’s issue is student fights.