A buyer who purchased a counterfeit Jean-Michel Basquiat from an art gallery that had acquired the painting a year earlier from Christie’s Inc. can sue the auction house for fraud and may be entitled to punitive damages, a state court has ruled.

Guido Orsi, who paid the Tony Shafrazi Gallery Inc. $185,000 for the untitled work 17 years ago, alleges that Christie’s passed off the painting as genuine at a 1990 auction, even though Basquiat’s estate had expressed doubts to the auction house about its authenticity.