Chauca v. Abraham

A plaintiff is entitled to punitive damages under the New York City Human Rights Law (NYCHRL) where the wrongdoer’s actions amount to willful or wanton negligence, or recklessness, or where there is a “conscious disregard of the rights of others or conduct so reckless as to amount to such disregard.”Plaintiff, a physical therapy aide, sued her former employer and two supervisory employees for sex and pregnancy discrimination under the NYCHRL and Title VII. At trial, the court applied to the NYCHRL the standard for punitive damages found in Title VII. The jury found Defendants liable for pregnancy discrimination and awarded $10,500 in compensatory damages and $50,000 in pain and suffering. Plaintiff appealed, arguing that the district court erred in importing the Title VII standard. The Second Circuit certified to the Court of Appeals a question regarding the standard for finding a defendant liable for punitive damages under the NYCHRL. The Court of Appeals answered as set forth above. View "Chauca v. Abraham" on Justia Law