Lorraine Cullen, Complainant v. Nassau County Civil Service Commission, Respondents, and New York State…

Summary

The Court of Appeals affirmed the Appellate Division's order deleting a $1,000 compensatory damages award to Lorraine Cullen, holding that proof of actual emotional injury is required for such damages and that the statute does not require proof of specific intent to discriminate. The Court also noted that compensatory damages may be awarded for emotional injury when proven, but the award in this case lacked evidentiary support. Justice Jasen, in a separate concurrence, agreed with the result but argued the broader intent issue should await a future case.