On March 29, 2017, in Bistline v. Rogers, No. 4D16-4012, the Florida Fourth DCA granted certiorari review and quashed a trial court order granting the plaintiff’s motion to amend an intentional business tort complaint to include claim for punitive damages. Section 768.72(1), Florida Statutes (2016), provides in relevant part: “In any civil action, no claim for punitive damages shall be permitted unless there is a reasonable showing by evidence in the record or proffered by the claimant which would provide a reasonable basis for recovery of such damages.
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