An issue of New York law, which had been referred to the New York State Court of Appeals by the Second Circuit, has been decided. The issue was whether punitive damages were available against a municipality under New York City Human Rights Law. The New York State Court of Appeals, in Krohn v. Katt held that such damages were not available. (That Court's decision can be found here.) The Second Circuit allowed the parties to present letter briefs commenting on this decision. In light of the state court's decision, the Second Circuit, in Krohn v. Katt, held that the vacatur of the punitive damages award by the District Court was proper and affirmed. The Second Circuit decision can be found at the Second Circuit website. The decision is dated June 9, 2004.