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Keywords

damagesharassmentcivil rightscompensatory damages

damagesappealharassmentcompensatory damagesstatutory damages

Related Cases

Pollard v. E.I. du Pont de Nemours & Co., 532 U.S. 843, 121 S.Ct. 1946, 150 L.Ed.2d 62, 85 Fair Empl.Prac.Cas. (BNA) 1217, 80 Empl. Prac. Dec. P 40,512, 69 USLW 4419, 01 Cal. Daily Op. Serv. 4522, 2001 Daily Journal D.A.R. 5559, 14 Fla. L. Weekly Fed. S 307, 2001 DJCAR 2756

Facts

Sharon Pollard alleged that she was subjected to a hostile work environment due to sexual harassment by co-workers, which her supervisors failed to address. This harassment led to her taking medical leave for psychological assistance and ultimately resulted in her dismissal when she refused to return to the hostile environment. The District Court awarded her $300,000 in compensatory damages, the maximum allowed under the statutory cap, but noted that this amount was insufficient to fully compensate her.

Finding that Pollard was subjected to co-worker sexual harassment of which her supervisors were aware, and that the harassment resulted in a medical leave of absence for psychological assistance and her eventual dismissal for refusing to return to the same hostile work environment, the District Court awarded her, as relevant here, $300,000 in compensatory damages—the maximum permitted under 42 U.S.C. § 1981a(b)(3).

Issue

Is front pay considered an element of compensatory damages under the Civil Rights Act of 1991, and thus subject to the statutory cap imposed by that section?

The issue presented for review here is whether front pay constitutes an element of 'compensatory damages' under 42 U.S.C. § 1981a and thus is subject to the statutory damages cap imposed by that section.

Rule

Front pay is not an element of compensatory damages under the Civil Rights Act of 1991, and therefore, it is not subject to the statutory cap imposed by 42 U.S.C. § 1981a(b)(3).

Held: Front pay is not an element of compensatory damages under § 1981a and thus is not subject to the damages cap imposed by § 1981a(b)(3).

Analysis

The Supreme Court analyzed the statutory language and legislative history of the Civil Rights Act of 1991, concluding that front pay is a remedy authorized under § 706(g) of the Civil Rights Act of 1964. Since front pay is not included in the definition of compensatory damages under § 1981a, it is not subject to the statutory cap. The Court emphasized that distinguishing between front pay awarded in lieu of reinstatement and that awarded when reinstatement is possible would lead to inconsistent and unjust outcomes.

We conclude that front pay is not within the meaning of compensatory damages in § 1981a(b)(3), and thus front pay is excluded from the statutory cap.

Conclusion

The Supreme Court reversed the Sixth Circuit's decision, holding that front pay is not subject to the statutory cap on compensatory damages under the Civil Rights Act of 1991.

The judgment of the Court of Appeals is reversed, and the case is remanded for further proceedings consistent with this opinion.

Who won?

Sharon Pollard prevailed in the case because the Supreme Court ruled in her favor regarding the treatment of front pay under the Civil Rights Act.

The Court of Appeals agreed with Pollard's arguments but considered itself bound by Hudson.

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Keywords

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