United States Ninth Circuit

The district court's award of punitive damages in a Title VII sexual harassment suit where the jury awarded no compensatory damages and only one dollar in nominal damages, is vacated and remanded, where: 1) although the degree of reprehensibility of the defendant's conduct supported a substantial punitive damages award, and the district court’s $300,000 award matched the Title VII damages cap, the award was constitutionally excessive in light of the fact that the ratio of punitive to compensatory damages was 300,000 to 1; and 2) the highest punitive award supportable under due process was $125,000 because it was the highest award that maintained the required "reasonable relationship" between compensatory and punitive damages, and nonetheless was on the order of the damages cap in Title VII and proportional to the reprehensibility of the defendant's conduct.

Appellate Information

• Decided 10/24/2013
• Published 10/24/2013

Judges

• O’SCANNLAIN

Court

• United States Ninth Circuit

Counsel