elements of the tort of fraud or deceit in Maryland where the tort is committed by a defendant who knows that his representation is false, include the type of deliberate wrongdoing and evil motive that has traditionally justified the award of punitive damages. Id. at 235, 652 A.2d 1117. The buyers maintain that the evidence at trial was sufficient to support a finding, by a clear and convincing standard, that Wood acted with conscious knowledge of the falsity of the impressions she was giving the buyers, not merely with reckless disregard for the truth or falsity of those impressions, and therefore with “actual malice”; and thus it was a jury question whether punitive damages were warranted against her and hence against Irwin. See Embrey v. Holly, 293 Md. 128, 137, 442 A.2d 966 (1982) (<HOLDING>). Likewise, they maintain that the evidence
holding that punitive damages may be imposed against employer for tortious conduct of employee recognizing that an award of treble damages for an antitrust violation and punitive damages for common law tortious interference with business relations based on same conduct would be duplicative holding that punitive and treble damages cannot both be awarded and indicating that a special jury verdict in this situation would be appropriate holding that when an employee is injured by his employers tortious conduct his employer owes him damages and compensation under the act holding a court may not award punitive damages holding that erisa did not permit employee to bring claim for punitive damages against employer