In Abbott v. Forest Hill State Bank, 60 Md. App. 447, 483 A.2d 387 (1984), the Court considered whether a plaintiff could recover damages for conversion after a bank wrongfully repossessed his car, and the Court held that emotional distress damages weren't recoverable for loss in property value (resulting from property damage) because the court had already dismissed an underlying fraud claim. Id. at 456-58.