Black v. Pan American Laboratories, et al., No. 09-51092 (5th Cir. 2011)
Annotate this CasePlaintiff sued her former employer alleging various sex discrimination claims and a retaliatory termination claim under Title VII, 42 U.S.C. 2000e et seq., and the Texas Commission on Human Rights Act (TCHRA), Texas Lab. Code 21.001-21.556. A jury rendered a verdict in plaintiff's favor and awarded her $3,450,000 in back pay and compensatory and punitive damages. Applying Title VII's damages cap, the district court reduced the jury's award to a total of $500,000, representing $300,000 in backpay and $200,000 in compensatory and punitive damages. The employer appealed the judgment, arguing that there was insufficient evidence to support the jury's liability and punitive damages findings and plaintiff cross-appealed, arguing that the district court erred in its application of the damages cap. The court held that there was ample evidence by which the jury could conclude that the employer had a corporate culture hostile to women, that this discriminatory animus extended to its management, and that plaintiff's sex was a motivating factor in the employer's decision to terminate her. Consequently, the district court did not err in denying the employer's motion for judgment as a matter of law on plaintiff's discrimination termination claim and affirmed the compensatory damages award. The court also held that, although there was sufficient evidence to support the jury's verdict as to liability on plaintiff's quota claim, there was insufficient evidence to support its back pay reward. The court further held that the district court did not err in applying Title VII's compensatory and punitive damages cap. Accordingly, the court reversed and remanded as to the jury's $150,000 back pay award for plaintiff's quota claim and affirmed the remainder of the district court's judgment.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.