In Maxwell v. Gallagher, 709 A.2d 100 (D.C. 1998) the Court recognized that there has been "some uncertainty in our decisions over the years" as to whether any award of compensatory damages is required before punitive damages may be imposed. Maxwell, supra, 709 A.2d at 103. Consequently, the Court articulated the principle on which this court decides the issue: "The principle we derive [from our past decisions] is that, before punitive damages may be awarded, there must be a basis in the record for an award of actual damages, even if nominal." Id. The Court reversed the trial court's award of punitive damages in Maxwell, a case involving shares of stock because, although the trial judge imposed nominal damages of $ 1.00 to accompany a $ 75,000 award of punitive damages, she nonetheless "expressly found that appellees had proven no actual damages . . . ." Id. at 105. Therefore, "punitive damages could not be awarded." Id.