ratio “would utterly fail to” punish and deter the defendant); Williams v. Kaufman County, 352 F.3d 994, 1016 (5th Cir.2003) (stating that “any punitive damages-to-compensatory damages ‘ratio analysis’ cannot be applied effectively in cases where only nominal damages have been awarded”); Local Union No. 38, Sheet Metal Workers’ Int’l Ass’n v. Pelella, 350 F.3d 73, 88 (2d Cir.2003) (stating that “the ratios referred to in [State Farm] may not apply with equal force when punitive damages are compared to nominal damages”); DiSorbo v. Hoy, 343 F.3d 172, 187 (2d Cir.2003) (noting that, when nominal compensatory damages are awarded, “ ‘the use of a multiplier to assess punitive damages is not the best tool....’” (quoting Lee v. Edwards, 101 F.3d 805, 811 (2d Cir.1996))); Lee, 101 F.3d at 811 (<HOLDING>); Sherman v. Kasotakis, 314 F.Supp.2d 843, 871
holding that when compensatory damages are nominal a much higher ratio of punitive damages to compensatory damages can be contemplated holding that punitive damages do not need to be proportional to compensatory damages holding that punitive damages are available in an intentional discrimination action even if the jury does not assess compensatory damages holding compensatory and punitive damages constitute legal remedies holding that conduct must be beyond the fraud which supported compensatory damages to award punitive damages