Practice point: Whilea plaintiff may pray for relief in the form of punitive damages, the claim may not be pled as a separate cause of action. Similarly, while a plaintiff, if successful, may be entitled to attorneys' fees under the City's Human Rights Law, a claim for attorneys' fees may not be maintained as a separate cause of action.
Case: La Porta v. Alacra, Inc., NY Slip Op 06113 (1st Dep't September 22, 2016)
Here is the decision.
Tomorrow's issue: An action on an account stated.