Suburban Propane, a Division of National Distillers and Chemical Corp. v. Proctor Gas, Inc., and James Taranovich  ·  1992-01-09  ·  Second Circuit  ·  2 pin-cites  ·  pin 143 Vt. at 539

"Once general (compensatory) damages are established ..., punitive damages may be awarded on a showing of actual malice."

State v. International Collection Service, Inc.  ·  1991-05-24  ·  Supreme Court of Vermont  ·  pin 470 A.2d at 1162

“The relief available under § 2461(b) to a consumer who has been victimized by an unfair or deceptive commercial practice was fashioned in order to promote and encourage prosecution of individual consumer fraud claims.”