Bennett, et al. v. Nucor Corp., et al, No. 09-3831 (8th Cir. 2011)
Annotate this CasePlaintiffs, six current and former African-American employees, brought suit against Nucor alleging racial discrimination in violation of 42 U.S.C. 1981 and Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e-2000e-17. The district court denied plaintiffs' requests for class certification, granted summary judgment in favor of Nucor on several claims and the case proceeded to trial. A jury returned verdicts against Nucor and awarded each plaintiff monetary damages. The parties appealed and cross-appealed, contesting various rulings by the district court. The court held that the district court did not abuse its discretion in believing that evidence of a previous enforcement action alleging race discrimination at the Blytheville plant was relevant to the credibility of plaintiffs' allegations. The court also held that the district court properly admitted certain statements at issue. The court further held that because Nucor failed to renew its motion under Rule 50(b), the court was without power to disturb the district court's entry of judgment on the jury's punitive damages award. The court finally held that the district court did not abuse its discretion by concluding that plaintiffs had not met their burden of demonstrating the commonality of their claims and that summary judgment was warranted on plaintiffs' disparate impact claims, failure-to-train disparate treatment claims, and failure-to-promote disparate treatment claims. Accordingly, the judgment of the district court was affirmed.
Court Description: Civil case - Employment Discrimination. District court did not abuse its discretion by admitting several types of evidence describing discrimination against nonparties at the plant where plaintiffs worked; district court did not err in overruling defendant's objections to certain statements made by plaintiff's counsel during closing argument; as a result of defendant's failure to renew its motion for judgment as a matter of law on the claim for punitive damages after entry of judgment, the court is without power to disturb the judgment on the jury's punitive damage award; district court did not err in denying plaintiff's motion to certify a broader class of all African Americans employed at the plant since 1999 for lack of commonality, as the extensive class certification record demonstrated that defendant's departments varied widely in their employment practices, working environments and functions; district court did not err in granting defendant summary judgment on plaintiffs' individual disparate impact claims, failure-to-train disparate treatment claims and failure-to-promote disparate treatment claims as the plaintiffs either failed to make a submissible case on the claims or failed to rebut defendant's legitimate proffered reason for a promotion decision.
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