In Turley v. ISG Lackawanna, Inc., 774 F.3d 140 (2d Cir. 2014) (No. 13-561), plaintiff employee brought a Title VII action against his employer, after he endured an extraordinary and steadily intensifying drumbeat of racial insults, intimidation and degradation over a period of more than three years, which was condoned and participated in by his supervisors. The jury awarded plaintiff $1.32 million in compensatory damages and $24 million in punitive damages. The district court subsequently granted a motion for remittitur, reducing the punitive damages award to $5 million, which was accepted by the plaintiff. On appeal, the Second Circuit held that the reduced punitive damages award was still excessive, and remanded for further remittitur proceedings. The court ruled that while the record was sufficient to support a finding that the conduct was egregious in the extreme, the 4-to-1 ratio of punitive to compensatory damages was excessive given that the compensatory damages were for emotional damages, which are inherently intangible, immeasurable and therefore imprecise. The court reasoned that its commitment to reducing arbitrariness in damages awards, reining in excessiveness, and ensuring some degree of proportionality weighed in favor of enforcing a tighter relationship between the harm suffered and the punishment imposed. Thus, the court concluded that a 2-to-1 ratio of punitive damages constitutes the maximum allowable in these circumstances.