SC21013 - McCarter & English, LLP v. Jarrow Formulas, Inc. ("This case, which comes to us upon our acceptance of a certified question from the United States District Court for the District of Connecticut, requires us to consider whether a law firm can recover punitive damages from a former client for the client's breach of contract. We have long recognized that the principal purpose of remedies in a breach of contract action is to provide compensation for loss. See, e.g., Vines v. Orchard Hills, Inc., 181 Conn. 501, 506, 435 A.2d 1022 (1980). As a result, damages for breach of contract are traditionally limited to compensatory damages. See, e.g., id., 506–507. Connecticut is unique among the states because common-law punitive damages are limited to litigation expenses that may also serve to compensate the plaintiff. See, e.g., Berry v. Loiseau, 223 Conn. 786, 827, 614 A.2d 414 (1992). But we have also recognized that, "in . . . light of the increasing costs of litigation," punitive damages can also "punish and deter wrongful conduct." Id. Consequently, punitive damages are often in tension with the purpose of damages in contract law because, "[e]ven if the breach [of contract] is deliberate, it is not necessarily blameworthy." Patton v. Mid-Continent Systems, Inc., 841 F.2d 742, 750 (7th Cir. 1988). In light of this tension, we tread carefully when determining whether to broaden the scope of a client's potential liability to its attorney when that attorney brings a breach of contract action against the client. After consideration of the common law of this state and other jurisdictions, and the relevant policy implications, we agree with, and adopt, the rule followed by the majority of jurisdictions and the Restatements: a law firm may not recover common-law punitive damages for its client's breach of contract unless it pleads and proves the existence of an independent tort for which punitive damages are available.")