Therefore, since the Sixth Circuit did not find the actions of First American to be sufficiently reprehensible, the court held that an award of punitive damages was inappropriate in the case at bar.This ruling by the Sixth Circuit Court of Appeals reflects a developing trend throughout the nation of applying a stricter standard to the award of punitive damages in cases involving covenants not to compete.1 487 F.3d 985 (6th Cir. 2007).2 538 U.S. 408 (2003).