VERONIKA CHAUCA, Plaintiff-Appellant, v. JAMIL ABRAHAM, individually, PARK MANAGEMENT SYSTEMS, LLC, a.k.a. Park Health Center, ANN MARIE GARRIQUES, individually, Defendants-Appellees., 841 F.3d 86

Summary

HOLDINGS: [1]-The question of the standard for finding a defendant liable for punitive damages under New York City, N.Y., Admin. Code § 8-502 was certified to the New York Court of Appeals where it was unclear whether New York City, N.Y., Admin. Code § 8-130, which identified a handful of code provisions that had been interpreted too narrowly by the courts, was intended to legislatively override federal case law, the standard for evaluating punitive damages claims involved competing policy concerns, and clarity as to the appropriate standard would permit the appellate court to determine whether the district court erred in deciding that a separate jury instruction was not warranted under the New York City Human Rights Law.