In Kolstad v. Am. Dental Ass'n, 527 U.S. 526, 528, 144 L. Ed. 2d 494, 119 S. Ct. 2118 (1999), the United States Supreme Court established an affirmative defense to punitive damages in employment discrimination cases, stating that "in the punitive damages context, an employer may not be vicariously liable for the discriminatory employment decisions of managerial agents where the decisions are contrary to the employer's good faith efforts to comply with Title VII."