Does a trustee's breach of fiduciary duty - without evidence of fraud or malice - warrant punitive damages?

Does a trustee's breach of fiduciary duty - without evidence of fraud or malice - warrant punitive damages?

In 2022 the Florida Rules of Appellate Procedure changed to allow district courts of appeal to review orders granting or denying leave to amend to add a claim for punitive damages by interlocutory appeal. That rule change has triggered a flood of appellate decisions clarifying the pleading and evidentiary requirements necessary to claim punitive damages in all sorts of cases, including cases against trustees for breach of fiduciary duty. When ca…