Punitive damages are awarded in addition to actual damages in certain circumstances. Punitive damages are considered punishment and are awarded when the defendant's behavior is found to be especially harmful, but are normally not awarded in the context of a breach of contract claim. See e.g. O'Gilvie Minors v. United States 519 US 79 (1996). See also Honda Motor Co. v. Oberg 512 US 415 (1994).