ANDERSON, J.:
After being injured in a brawl outside of a bar, James Mellen brought a civil action for assault and battery against David Patrick Lane. The Master-in-Equity found Lane liable for Mellen's injuries, awarding Mellen $200,000 in actual damages, but declining to award punitive damages. Lane contends the Master erred in determining his actions were the proximate cause of Mellen's injuries. Mellen maintains the Master erred by denying punitive damages. We...
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