applies where the plaintiff complains of retaliatory conduct violative of § 215(a)(3). Our Court of Appeals has not addressed this issue. Only two courts of appeals have definitively answered whether punitive damages are available under the FLSA. They reached contrary results. See Travis v. Gary Comty. Mental Health Ctr., Inc., 921 F.2d 108 (7th Cir.1990) (finding punitive damages are available for a retaliation claim under the FLSA); but see Snapp v. Unlimited Concepts, Inc., 208 F.3d 928 (11th Cir.2000) (finding punitive damages are not available for a retaliation claim under the FLSA). One court in this District found that punitive damages are available for a retaliation claim under the FLSA. See Marrow v. Allstate Sec. & Investigative Servs., Inc., 167 F.Supp.2d 838 (E.D.Pa.2001) (<HOLDING>). In Travis, the Court of Appeals for the
holding punitive damages not recoverable for retaliatory discharge claim under general maritime law holding that punitive damages are recoverable in a claim for retaliation under the flsa holding that punitive damages are not allowed under the flsa holding under flsa holding punitive damages available for retaliatory claim under flsa