Per Curiam.
I
In light of the disposition of this case by the court of appeals, we must first examine whether the issue of Spartan's liability for punitive damages was properly before the jury.
Appellant argues that the following facts establish a basis for awarding punitive damages against Spartan:
"(1) Spartan's agents shouted at the children to move away from their original safe play area, causing Jun Ku An to move to the mud puddle...
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