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The Ninth Circuit
U.S. Court of Appeals struck down a punitive damages award that was 100
times the compensatory damages awarded in the case. An uncompensated volunteer was not an "employee" for purposes of imposing liability under the Fair Employment and Housing Act. The new Class Action Fairness Act of 2005 is not retroactive and thus applies only to cases filed after the Act became law in February, 2005.
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