Plaintiff filed suit against various Defendants, including De Amigos, LLC, the operator of Spot Lounge, D.C. arising from an alleged sexual assault. One of Plaintiff’s claims against De Amigos, LLC was for reckless and willful disregard based upon De Amigos, LLC’s alleged failure to check Plaintiff’s identification, providing or selling alcohol to Plaintiff at age 18, and continuing to serve alcohol to Plaintiff when she was visibly intoxicated. De Amigos, LLC filed a Motion for Partial Summary Judgment or, in the Alternative, Motion to Dismiss Count VI of the Complaint (the reckless and willful disregard count). Defendant argued that a claim for reckless and willful disregard was not recognized under District of Columbia law. Plaintiff argued that Count VI was a claim for punitive damages. The United States District Court for the District of Columbia held that a claim for reckless and willful disregard was not an actionable claim under District of Columbia law. With respect to Plaintiff’s punitive damages argument, the Court held that punitive damages are a remedy and not a cause of action.