Practice point: New York does not recognize an independent cause of action for punitive damages.
Student note: Questions of law which appear on the face of the record and which could not have been avoided if raised at the proper juncture may be raised for the first time on appeal.
Case: Muniz v. Mount Sinai Hosp. of Queens, NY Slip Op 00192 (2d Dept. 2012).
Tomorrow’s issue: Res ipsa loquitur.
