Joyce v. Town of Dennis, No. 11-1928 (1st Cir. 2013)
Annotate this CasePlaintiff, a female, brought federal and state claims alleging gender discrimination against the Town of Dennis, Massachusetts, the Town golf course, and several individuals after the golf course refused to let Plaintiff participate in a men's golf tournament. The district court granted summary judgment for Plaintiff and held a trial on damages. The court ruled (1) awarded Plaintiff $34,600 in attorney's fees and costs, (2) rejected Plaintiff's request that the jury be instructed on punitive damages, (3) denied Plaintiff's request for an injunction ordering Defendants to adopt a policy barring gender-based discrimination. Both parties appealed, challenging the nature and extent of Plaintiff's remedy. The First Circuit Court of Appeals (1) affirmed the district court's treatment of punitive damages; (2) vacated the denial of injunctive relief where the district court failed to explain its decision to grant or refuse such relief; and (3) vacated the award of attorney's fees, holding that the district court erred in reducing Plaintiff's requested award based on, inter alia, Plaintiff's rejection of a settlement offer.
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