New Hampshire

Dimick v. Schiedt in New Hampshire Law

How Dimick v. Schiedt applies in New Hampshire: state-specific rules, key cases, and bar exam notes for Civil Procedure.

State Approach

New Hampshire follows the general principle that a court should not impose punitive damages unless the harm is found to be intentional or grossly negligent, emphasizing the necessity of direct causation. This aligns with the principles set forth in Dimick v. Schiedt regarding the limitations of jury discretion in awarding damages.

State Rule
In New Hampshire, punitive damages may be awarded only when there is clear and convincing evidence of malice or willful intent to cause injury, consistent with the precedent established in Dimick v. Schiedt.
Significant State Cases

Ambrogio v. Lane

The New Hampshire Supreme Court upheld the dismissal of punitive damage claims due to insufficient evidence of malicious intent.

Griffin v. Doc’s Place, Inc.

The court reaffirmed that punitive damages require clear intent and cannot be based solely on negligence.

Cousins v. New Hampshire Hospital

The court ruled that punitive damages were not warranted due to lack of clear evidence of willful conduct.

Comparison to Federal Law

New Hampshire's approach to punitive damages closely mirrors the federal standard in terms of requiring clear and convincing evidence of intent or recklessness. However, New Hampshire emphasizes the necessity of direct causation more strictly than some federal circuits, which may allow for broader interpretations of harm.

Bar Exam Note

Understanding the limitations on punitive damages as articulated in Dimick v. Schiedt is crucial for the New Hampshire bar exam, particularly in Civil Procedure and Tort Law sections.

Practice Pointers
  • Always establish a clear link between the defendant's conduct and the harm to support punitive damage claims.
  • Review New Hampshire statutes and case law for specific procedural requirements in pleading exceptional damages.
  • Be prepared to argue both factual and evidential basis for the award of punitive damages, in line with established state precedent.

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