of the award of counsel fees and punitive damages. In its statement of the issues presented on this appeal, the appellants made no reference to compensatory damages. It may well be that plaintiffs’ counsel consider that damages awarded for humiliation or embarrassment are punitive and not compensatory. If so they misunderstand basic damages principles. If the action of the defendant created mental suffering to the plaintiffs, that is actual damage which. can be recovered without establishing the reckless conduct prerequisite for an award of punitive damages. See Gostkowski v. R.C. Church of the Sacred Hearts, 262 N.Y. 320, 324, 186 N.E. 798 (1933); C. McCormick, Damages § 88, at 315-16 & n.5 (1935); see Note, Exemplary Damages in the Law of Torts, 70 Harv.L.Rev. 516, 520-21 (1957) (<HOLDING>). In* any event, the record is clear that
recognizing that the unbroken line of judicial authority in all but three states would seem to preclude any argument that exemplary damages in theory retain any major compensatory character holding that a further finding that the insured intended to injure the defendant would preclude any liability for the insurer for indemnification of compensatory or punitive damages holding that procedural due process does not require the jury to be instructed that a reasonable relationship must exist between the amounts of compensatory and exemplary damages holding that provision in wrongful death act that allowed parents to recover exemplary damages was invalid under art 16  26 since legislature could not enlarge on exemplary damages holding the eighth amendment inapplicable to an award of exemplary damages