of Torts § 909 (1979); Restatement (Second) of Agency § 217C (same). Because the alleged wrongdoer was not a manager, the employer had not authorized or ratified the violations, and the employer was not negli gent in hiring her, the court denied punitive damages against the employer. Fitzgerald, 68 F.3d at 1263-64. The Court holds that the same result should follow in the present case. Federal law governs damages in civil rights cases, see 42 U.S.C. § 1988(a), and the Restatement serves as a reasonable starting point for determining the correct legal standards. This Court adopts the reasoning of Fitzgerald and holds that the Restatement (Second) of Torts § 909 standards control in claims for punitive damages under § 1981. Cf. Miller v. Bank of America, 600 F.2d 211, 213 (9th Cir.1979) (<HOLDING>). Applying these standards to the present case,
holding that supervisory employee is not an employer under the terms of cfepa and because the employer is liable for the employees actions a plaintiff may not maintain an action against the employee individually under conngenstat  46a60 holding that an employer alone is liable for a violation of title vii by supervisory employees holding that the individual defendant does not have to be in privity of contract with the plaintiff to be held liable under  1981 holding that individuals can be held liable under  1981 only when they have been personally involved or directly participated in the discrimination holding that employer may be held liable under  1981 for discrimination by supervisory employee