Plowing new ground in the 2nd Circuit, Judge Arthur D. Spatt of the U.S. District Court for the Eastern District of New York has ruled that a jury may award punitive damages in a Title VII employment discrimination case even though it finds the plaintiff is not entitled to compensatory damages.

The ruling in Cush-Crawford v. Adchem Corp., 98-CV-676, preserved a jury verdict awarding a Long Island woman $100,000 in punitive damages on a sexual harassment claim, but denying her any compensatory damages.