court to award punitive damages. See Loomis Elec. Prot., Inc. v. Schaefer, 549 P.2d 1341, 1343 (Alaska 1976); Arthur Young & Co. v. Sutherland, 631 A.2d 354, 372 (D.C.1993); Ellis v. N.D. State Univ., 764 N.W.2d 192, 203 (N.D.2009); Rice v. CertainTeed Corp., 84 Ohio St.3d 417, 704 N.E.2d 1217, 1220-21 (1999); Haynes v. Rhone-Poulenc, Inc., 206 W.Va. 18, 521 S.E.2d 331, 346-48 (1999). In Connecticut, an apparent split of authority exists among the superior courts regarding the power of the court to award punitive damages. Compare Collier v. State, No. CV96-80659, 1999 WL 300643, at ⅞3-4 (Conn.Super.Ct. May 3, 1999) (permitting a district court to award punitive damages), with Wright v. Colonial Motors, Inc., No. CV116008335, 2012 WL 2044635, at ⅜1-2 (Conn.Super.Ct. May 16, 2012) (<HOLDING>). Some of the courts that have rejected
holding a court may not award punitive damages holding that punitive damages are not fines holding that proportionality is not the touchstone for a punitive damages award holding that evidence of a defendants financial condition is a prerequisite to an award of punitive damages holding that conduct must be beyond the fraud which supported compensatory damages to award punitive damages