On May 28, 2024, the First Department issued a decision in Hall v. Middleton, 2024 NY Slip Op. 02889, holding that punitive damages can be awarded even if there is no compensatory damages award, explaining:
The trial court also providently exercised its discretion in awarding $1 million in punitive damages. Punitive damages may be awarded in connection with an underlying claim for a breach of fiduciary duty like the one at issue here. Contrary to Middleton, a related award of compensatory damages is not required. Based on the facts and evidence herein, it was entirely appropriate to grant equitable relief and also exact punitive damages as a deterrent against flagrantly unlawful conduct and is entirely consonant with substantive legal and equitable principles and with present-day concepts of procedural efficiency. The trial court explained its rationale for the amount of the award, which appropriately included consideration of the harm done, the flagrancy of the conduct, and the impact on Middleton. Although defendants complain that the court did not consider Middleton’s wealth, they do not point to any evidence that was not considered and their request for a bifurcated trial was not raised below.
(Internal quotations and citations omitted).