Quan v. TAB GHA F&B, Inc., Civ. No. TDC-18-3397, 2021 WL 4129115, at *3 (D. Md. Sept. 10, 2021) (internal quotation marks omitted) (quoting Allen v. Kavasko Corp., Civ. No. WMN-15-1839, 2015 WL 8757799, at *1-*2 (D. Md. Dec. 15, 2015)).
Quan v. TAB GHA F&B, Inc., Civ. No. TDC-18-3397, 2021 WL 4129115, at *3 (D. Md. Sept. 10, 2021) (internal quotation marks omitted) (quoting Allen v. Kavasko Corp., Civ. No. WMN-15-1839, 2015 WL 8757799, at *1-*2 (D. Md. Dec. 15, 2015)). A plaintiff may be awarded punitive damages if she demonstrates that a defendant possessed “evil motive, intent to injure, ill will, or fraud, i.e., ‘actual malice.'” Ellerin v. Fairfax Sav., F.S.B., 652 A.2d 1117, 1125 (Md. 1995); Quan, 2021 WL 4129115, at *3.
In default judgment cases involving fraud, the punitive damages in this District appear to generally range from approximately half to double the compensatory damages award. See, e.g., Quan v. TAB GHA F&B, Inc., Civ. No. TDC-18-3397, 2021 WL 4129115, at *4 (D. Md. Sept. 10, 2021), report and recommendation adopted, Civ. No. TDC-18-3397, 2021 WL 6881288 (D. Md. Nov. 9, 2021) (awarding punitive damages of $250,000 and compensatory damages were $500,000); Allen v. Kavasko Corp., Civ. No. WMN-15-1839, 2015 WL 8757799, at *2 (D. Md. Dec. 15, 2015) (awarding punitive damages of $89,530.20 and compensatory damages of $89,530.20); Recycling Sols., Inc. v. Orrs' Env't, LLC, Civ. No. PWG-14-1062, 2015 WL 3948981, at *10 (D. Md. June 26, 2015) (awarding punitive damages of $100,000 and compensatory damages of $88,521); Legacy Inv. & Mgmt., LLC v. Susquehanna Bank, Civ. No. WDQ-12-2877, 2014 WL 5325757, at *11 (D. Md. Oct. 17, 2014) (awarding punitive damages of $300,000 and compensatory damages of $159,293.14).
“Punitive damages are available under Maryland law in tort actions to punish a defendant ‘for egregiously bad conduct toward the plaintiff, [and] also to deter the defendant and others contemplating similar behavior.'” Allen v. Kavasko Corp., No. WMN-15-1839, 2015 WL 8757799, at *1-2 (D. Md. Dec. 15, 2015) (quoting Bowden v. Caldor, Inc., 350 Md. 4, 22, 710 (1998)). A plaintiff may only be awarded punitive damages if there is a showing of actual malice.