of a check or draft when person who executed and delivered the check possessed fraudulent intent in not paying the holder the full amount within 30 days); Tenn.Code Ann. § 48-101-520(b)(l) (1995) (court may award treble damages if defendant's use of an unfair, false or misleading solicitation of charitable funds was willful or knowing); Tenn.Code Ann. § 62-37-105(e) (1990) (one who engages in the construction or home improvement business without a license may be subject to treble damages). 8 . Some courts have interpreted a statute declaring itself to be a non-exclusive remedy to entitle plaintiffs to recover both treble damages under the statute and punitive damages pursuant to a common law claim in a single action. See, e.g. Rhue v. Dawson, 173 Ariz. 220, 841 P.2d 215, 228 (1992) (<HOLDING>); Toyota of Florence v. Lynch, 314 S.C. 257,
holding that treble damages awarded under the civil theft statute are remedial not punitive holding tcpa is remedial statute and that statutory damages are not punitive damages holding treble damages under the civil theft statute are punitive holding that a plaintiff may receive both treble damages under rico and state law punitive damages for the same course of conduct holding that plaintiff could recover both treble damages under state racketeering statute and punitive damages under fraud and breach of fiduciary duty claims because the statute provided that actions brought under it are remedial and not punitive and that civil remedies provided under it are supplemental and not mutually exclusive