In Embrey v. Holly, 293 Md. 128, 442 A.2d 966 (1982), the Maryland Court of Appeals upheld a punitive damage award against an employer.  The court ruled that the "tortious act of the servant done in the course of his employment is ordinarily the legal act of the master, and in this sense, the employer is not free of ‘fault.”’ omitted).  This opinion has not been disturbed by Zenobia or any subsequent case or statute.