Where police officers commit serious breaches of fundamental rights including unlawful arrest, trespass to person, and false imprisonment in humiliating circumstances, exemplary damages must be substantial enough to bring home to the State that such conduct is not accepted. In this case, $120,000 in exemplary damages and $25,000 in aggravated damages were awarded (in addition to $25,000 general damages) where officers dragged the plaintiff from her home without informing her of any charge, ripped her clothing, and detained her for hours in a state of undress while fabricating evidence. Aggravated and exemplary damages should be separately assessed.
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