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Allapattah Services, Inc. v. Exxon Corporation

United States District Court for the Southern District of Florida
61 F.Supp.2d 1326 (1999)



Allapattah Services, Inc. and several other dealers (plaintiffs) were operating under a sales agreement with Exxon Corporation (Exxon) (defendant). A dispute arose, and the dealers filed a class-action suit against Exxon for breach of contract. Shortly before trial, the plaintiffs moved to add a claim for punitive damages on the ground that Exxon’s breach was in bad faith. Exxon argued (1) that punitive damages were inappropriate in a case based solely in contract rather than tort, (2) that adding the claim so close to trial would be prejudicial, and (3) that the law governing punitive damages varied too much across states for a diversity class action.

Rule of Law


Holding and Reasoning (Gold, J.)

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