Law Third, Torts: Liability for Economic Harm, 89 A.L.I. Proc. 22, 46-47 (2012). The A.L.I. states that “[o]nce it is approved by the membership at an Annual Meeting, a Tentative Draft . . . represents the most current statement of the American Law Institute’s position on the subject and may be cited in opinions or briefs . . . until the official text is published.” Overview, Project Development, Am. Law Inst., http://www.ali.org/index. cfm?fuseaction=projects.main. 4 I add the “exeept-when-it-doesn’t” caveat because courts have recognized a host of exceptions to this general principle, such that the broad statement quoted above doesn’t actually reflect the state of the law. See, e.g., Long Trail House Condo. Ass’n v. Engelberth Constr., Inc., 2012 VT 80, ¶ 13, 192 Vt. 322, 59 A.3d 752 (<HOLDING>) (quotations omitted); Springfield
holding that defendant may be liable in tort when it has breached a duty of reasonable care distinct from its contractual obligations because a tort obligation is a duty imposed by law  apart from and independent of promises made and therefore apart from the manifested intention of the parties to a contract holding that the law imposes on every person who enters upon an active course of conduct the positive duty to exercise ordinary care to protect others from harm and calls a violation of that duty negligence  that a complete binding contract between the parties is not a prerequisite to a duty to use due care in ones actions     and that architects may be held liable for a breach of the duty of care and breach of contract that results in foreseeable injury economic or otherwise holding that a duty of care may arise out of a contractual relationship between two parties recognizing that the duty arises not from the terms of the insurance contract but from an obligation imposed in law as a result of the special relationship recognizing that there might be recovery for purely economic losses in a limited class of cases involving parties who have a special relationship which creates a duty of care independent of contract obligations such as the obligation to avoid violating a professional duty