. See also Kauffman v. Maxim Healthcare Servs., Inc., 509 F.Supp.2d 210, 220 n.13 (E.D.N.Y. 2007) (“[U]nlike Title VII, Section 1981 does not have a statutory cap that limits punitive damages.”) (citing 42 U.S.C. § 1981a(b)(4)); Hill v. Airborne Freight Corp., 212 F.Supp.2d 59, 77 n.11 (E.D.N.Y. 2002) (“That [plaintiff's] retaliation claim was also pled under Title VII, which does have a cap on compensatory and punitive damages . . . is of no consequence because, as previously noted, he can recover these damages under either § 1981 or New York City Human Rights Law.”)), aff'd, 93 Fed.Appx. 260 (2d Cir. 2004)).

The closest analogous civil penalty relating to Plaintiff's claims is one pursuant to Title VII. See Kauffman v. Maxim Healthcare Servs., Inc., 509 F. Supp. 2d 210, 220 (E.D.N.Y. 2007). Congress has capped the total damages for future pecuniary losses, nonpecuniary losses, and punitive damages in Title VII cases at $300,000.

unitive damage award where “there was evidence that [plaintiff] suffered significant psychological and emotional distress as a direct result of [her supervisor's] sexually harassing behavior.... There was also ample evidence that [plaintiff] was in a precarious financial situation during the period of harassment, that [her supervisor] knew about that situation, and that he used it to his advantage in exerting his power over her. [The supervisor's] harassment of [plaintiff] was not an isolated incident, but rather it began shortly after the start of her employment and continued largely unabated until her termination. Finally, as the jury concluded in awarding punitive damages, [the supervisor's] harassment of [plaintiff], and [the] retaliatory termination, were not mere accidents. [The supervisor] intentionallymanipulated the terms and conditions of [plaintiff's] employment both to pursue his goal of a romantic relationship with her and to penalize her when she spurned his advances.”); Kauffman v. Maxim Healthcare Servs., Inc., 509 F.Supp.2d 210 (E.D.N.Y.2007) (remitting a $1.5 million punitive damage award to just over $500,000, where the court found that “[t]here is evidence in the record from which the jury could have concluded that the degree of reprehensibility of Defendant's conduct was substantial. Plaintiff endured sexist and racist remarks throughout his tenure with Defendant.

under § 1981 are not subject to Title VII's statutory cap. See Kauffman v. Maxim Healthcare Servs., Inc., 509 F.Supp.2d 210, 220 (E.D.N.Y. 2007).

"[U]nlike Title VII, Section 1981 does not have a statutory cap that limits punitive damages." Kauffman v. Maxim Healthcare Servs., Inc., 509 F. Supp. 2d 210, 220 (E.D.N.Y. 2007) (citations omitted).

(citing 42 U.S.C. § 1981a(b)(3)(A) -(D)), adopted as modified, 2012 WL 1744744 (E.D.N.Y. May 15, 2012); Walia v. Vivek Purmasir & Assocs., Inc., 160 F.Supp.2d 380, 389 (E.D.N.Y. 2000) (noting that the amount of compensatory damages for a respondent who has more than 14 but fewer than 101 employees shall not exceed $50,000) (citing 42 U.S.C. § 1981a(b)(3)(A)). However, where Title VII claims are pled alongside Section 1981 and NYCHRL claims, courts have awarded damages in excess of the Title VII statutory cap since those statutes impose no limit on the amount of compensatory or punitive damages a court may award See Manswell, 2017 WL 4075180, at *2 n.3 (collecting authorities); Rodriguez, 2014 WL 1347369, at *6 n.4; Caravantes v. 53rdStreet Partners, LLC, No. 09 Cv. 7821(RPP), 2012 WL 3631276, at *21 (S.D.N.Y. Aug. 23, 2012) (citations omitted); Kauffman v. Maxim Healthcare Servs., Inc., 509 F.Supp.2d 210, 220 (E.D.N.Y. 2007). While the NYSHRL does not provide for punitive damages, it does not limit compensatory damages in employment discrimination cases.

Courts typically look to Title VII as providing analogous statutory remedies to Section 1981 claims. See Swinton v. Potomac Corp., 270 F.3d 794, 820 (9th Cir. 2001) (collecting cases); Kauffman v. Maxim Healthcare Servs., Inc., 509 F. Supp. 2d 210, 220 (E.D.N.Y. 2007) (collecting cases). The large discrepancy between Title VII's $50,000 cap for compensatory and punitive damages and the jury's $1 million punitive award weigh in favor of remittitur.

If Plaintiff does not accept (1) a remittitur to $1.5 million of the punitive damage award against Wey on Plaintiff's defamation claim; and (2) a remittitur to $1.5 million of the punitive damage award against FNL Media on Plaintiff's defamation claim, this Court will vacate the punitive damage awards against these defendants and conduct a new trial limited to the question of damages. SeeKauffman v. Maxim Healthcare Serv., Inc., 509 F.Supp.2d 210, 221 (E.D.N.Y.2007) (citing Vasbinder, 976 F.2d at 122 ). CONCLUSION

The health and safety of people other than Mitri were not implicated. Third, Walgreens was Mitri's employer, meaning that Mitri was dependent upon Walgreens for his livelihood. See Planned Parenthood of the Columbia/Willamette, Inc., v. American Coalition of Live Activists, 422 F.3d 949, 959-60 (9th Cir. 2005); Kauffman v. Maxim Healthcare Servs., Inc., 509 F.Supp.2d 210, 217 (E.D. N.Y. 2007). Walgreens's termination also deprived Mitri of a job that he thoroughly enjoyed and found especially satisfying.

Because there is no cap on punitive damages under § 1981, as there is for Title VII, the jury's award for Title VII violations is apportioned to § 1981. See, e.g., Funk v. F & K Supply, Inc., 43 F.Supp.2d 205, 225 (N.D.N.Y.1999); Gonzalez v. Bratton, 147 F.Supp.2d 180, 204 (S.D.N.Y.2001); Kauffman v. Maxim Healthcare Servs., Inc., 509 F.Supp.2d 210, 220 n. 13 (E.D.N.Y.2007). This Court agrees.