The claim is dismissed, as no separate cause of action for punitive damages lies for pleading purposes. Even if it were properly pleaded, the claim does not lie in an action that is grounded on private breach of contract, and does not seek to vindicate a public right or deter morally culpable conduct.
Ahsanuddin v. Addo, NY Slip Op 06864 (1st Dep't September 26, 2019)
Here is the decision.