Haw. Rev. Stat. § 663-1.2 – Tort liability for breach of contract; punitive damages.

No person may recover damages, including punitive damages, in tort for a breach of a contract in the absence of conduct that:

(1) Violated a duty that is independently recognized by principles of tort law; and
(2) Transcended the breach of the contract.

[L 1999, c 237, §1]

Russ Francis v. Lee Enterprises: Hawai‘i Turns Away From Tortious Breach of Contract. 23 UH L. Rev. 647 (2001).