Ganci filed a lawsuit against Townsend in July 2010 alleging sexual harassment and intentional infliction of emotional distress. Ganci’s claims were based, in part, on an alleged sexual assault in the workplace, text messages and voice mails of a sexually explicit nature, and attempts to initiate a sexual relationship over an extended period of time. At trial, the jury held for Ganci on her sexual harassment claim but rejected her claim of emotional distress. The jury awarded Ganci \($450,000\) in compensatory damages and \($100,000\) in punitive damages against Townsend. The trial court set aside the punitive damages award after determining that such damages were not available under federal or New York law. Townsend filed a Chapter 7 bankruptcy petition seeking to discharge the judgment entered in Ganci’s favor. Ganci commenced a proceeding in Townsend’s bankruptcy seeking a determination that the judgment was non-dischargeable. The US Bankruptcy Court for the Eastern District of New York agreed with Ganci and held that the judgment was non-dischargeable as it was based upon a willful and malicious injury. Townsend appealed the ruling to the district court and claimed that the jury’s rejection of Ganci’s emotional distress claim established that he did not act willfully. How should the court define “willful” for purposes of determining whether Townsend was entitled to a discharge? Is the rejection of Ganci’s emotional distress claim and punitive damages award relevant to this determination?