United States First Circuit

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Dimanche v. MBTA, 17-1169

In this wrongful employment termination case, the appellate court affirmed the judgment of the trial court awarding 1.3 million in damages on the discrimination claim and 1.3 million in punitive damages. Defendant appealed arguing insufficient evidence to support punitive damages; and reversible error for sanctions for removing entry of default and allowing hostile work environment theory not explicitly pled to go to the jury. The appellate court stated that defendant largely lost the appeal for failure to make appropriate objections and offers of proof before the trial court. Further, the appellate court stated that there was sufficient evidence to support the damages award both compensatory and punitive. The court agreed that the trial court erred by imposing a default sanction order, but there was no showing that defendant was prejudiced by it or by the hostile work environment claim.

Appellate Information

  • Argued
  • Submitted
  • Decided
  • Published 2018/06/18


  • Lynch


  • United States First Circuit


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