In 42 U.S.C. Section
1981 action, Eighth Circuit remits $6 million punitive damages award to
$600,000.
Williams v. ConAgra
Poultry Co., 378 F.3d 790 (8th Cir. August 6, 2004) - This is a 42 U.S.C.
Section 1981 action alleging wrongful termination and harassment. George
Williams, who is black, was a supervisor for ConAgra. He was terminated
after he quarreled with one of his supervisors and a co-worker. At trial,
the jury found in favor of Williams on the wrongful termination claim and
awarded $927,788.90 in compensatory damages and $6,063,750.00 in punitive
damages. The jury also found in favor of Williams on the hostile work
environment claim and awarded $1,001,397.40 in compensatory damages and
$6,063,750.00 in punitive damages. On the termination claim, the district
court remitted the award of compensatory damages to $173,156.00 and the
punitive damages award to $500,000.00. On the harassment claim, the district
court remitted the compensatory damages to $600,000.00, but let the punitive
damages award of $6,063.750.00 stand. On appeal, ConAgra argues that the
district court erred in admitting evidence of harassment of which Williams
was unaware. The Eighth Circuit finds no error. While the Court agrees that
Williams cannot recover for harassment of which he was unaware, there were
other reasons for admitting the evidence: (1) the evidence makes Williams'
testimony more credible in describing the environment that he was subjected
to; (2) evidence of widespread toleration of racial harassment makes it more
likely that Williams' termination was motivated by race; (3) Williams
claimed that he was terminated for complaining about a racially hostile work
environment at the plant, and therefore the extent of the hostile work
environment is probative on the matter of managerial motives; and (4) the
evidence is relevant on the issue of whether Williams was eligible for
punitive damages on his harassment claim. Next, ConAgra argues that the work
environment was not hostile as a matter of law. The Court reviews the facts
and disagrees. Next, ConAgra argues that the district court erred in
allowing the jury to award punitive damages on both the wrongful discharge
and the harassment claims. The Court disagrees because it finds sufficient
evidence that ConAgra intentionally discriminated with malice or reckless
indifference to the protected rights of Williams. Finally, ConAgra argues
that the punitive damages award on the harassment claim violates due
process. The Eighth Circuit agrees for three reasons: (1) in upholding the
award, the district court improperly relied upon evidence of misconduct by
ConAgra unrelated to Williams' claim; (2) the punitive damages award is far
in excess of what analogous statutes would allow; and (3) the ratio of
punitive damages to compensatory damages far exceeds the levels that the
Supreme Court has suggested are consistent with due process. Therefore, the
Court holds that due process requires that the punitive damages award be
remitted to $600,000.00.
