Municipal Liability: Refusal to Impute Punitive Damages to a Municipal Corporation for the Intentional Tort of an Employee

Williams v. City of New York, 508 F.2d 356 (2d Cir. 1974). In Williams v. City of New York the Second Circuit Court of Appeals denied an award of exemplary damages in a suit for malicious prosecution citing as authority numerous New York state cases. New York\u27s common law has refused to award punitive damages against a municipal corporation. Samuel Tito Williams was arrested in 1947 and accused in the murder of a young black girl. Williams\u27 guilt was established at trial almost solely by the admission of a confession obtained in a lengthy police custodial interrogation. The jury necessarily found in convicting him of murder that his confession was voluntarily given