Appeals. Preserving error. Defense failed to preserve argument that punitive damages may not be awarded against wrongdoer’s estate.

 Carpentier v.Tuthill, 2013 VT 91, ¶ 19 n.*

Defendant suggests in its brief that no punitive damages were appropriate because Oakes is dead, and thus, the award could have no deterrent effect.  Defendant did not argue below that, as a matter of law, the jury could not award punitive damages, and we consider these arguments waived. See Ferrisburgh Realty Investors v. Schumacher, 2010 VT 6, ¶ 27, 187 Vt. 309, 992 A.2d 1042 (holding that party waived argument that no punitive damages should have been awarded by failing to raise issue at trial or in motion for directed verdict at close of case). Thus, we do not reach the question of whether punitive damages can ever be rightfully awarded against an estate.