that is, act in a public role. See Garrity, 386 N.Y.S.2d 831, 353 N.E.2d at 795. The dissenting view, on the other hand, focused on the growing role and broadening scope of arbitration to resolve disputes. Id. 386 N.Y.S.2d 831, 353 N.E.2d at 798-801. {18} Since Garrity, many other jurisdictions have allowed punitive damages to be awarded in arbitration. Some jurisdictions permit arbitrators to award punitive damages only when they are expressly authorized by the contract. See Edward Elec. Co. v. Automation, Inc., 229 Ill.App.3d 89, 171 Ill.Dec. 13, 593 N.E.2d 833, 843 (1992) (determining arbitrators could award punitive damages, so long as there was an express provision in the agreement authorizing such relief). Complete Interiors, Inc. v. Behan, 558 So.2d 48 (Fla.Ct.App.1990) (<HOLDING>). {19} The federal courts, applying the Federal
holding that punitive damages may be awarded for egregious violations of the lmrda holding a court may not award punitive damages holding punitive damages claims must be stricken absent a reasonable evidentiary basis for their award holding arbitrators exceeded their power when they awarded punitive damages absent an express provision authorizing them holding what section 76872 requires is that a plaintiff who has pleaded punitive damages must offer a reasonable evidentiary basis for punitive damages and obtain an order authorizing the maintenance of the punitive damage claim as a predicate to conducting discovery of a defendants financial worth