Sanders v. Lee County Sch. Dist. No. 1, et al., No. 10-3240 (8th Cir. 2012)
Annotate this CaseAn Arkansas jury found in favor of plaintiff on her Title VII claims of race discrimination and constructive discharge against the school district and individual members of the County's Board of Education and awarded her compensatory damages, wage and fringe benefits, and punitive damages. Plaintiff subsequently appealed the district court's judgment. The court held that, under the circumstances, it believed that plaintiff presented sufficient evidence for a reasonable jury to conclude defendant was constructively discharged. Therefore, the court reversed the district court's decision to grant the Rule 50 motion on that claim. The court held that the jury was not instructed to consider whether the individual Board members affirmatively proved ignorance of federal law when discriminating against defendant on the basis of her race. Therefore, the court reversed the district court's Rule 50 motion vacating the punitive damage award, but remanded this issue to the district court. Because the court's resolution of the constructive discharge claim and the punitive damage awards directly affected the degree of success plaintiff obtained in her civil rights action, the court remanded the issue of attorneys' fees.
Court Description: Civil case - employment discrimination. Plaintiff presented sufficient evidence for a jury to conclude that she was constructively discharged when she was transferred from her position as finance coordinator to food services assistant on the basis of her race, and the district court erred in granting defendants' Rule 50 motion and setting aside the jury verdict on the constructive discharge claim; with respect to plaintiff's punitive damages claim, the district court's order granting defendants' Rule 50 motion is vacated, and the matter is remanded to allow plaintiff to prove her claim, subject to the defendants' right to assert the affirmative defense of ignorance of federal law; the court's disposition of the appeal directly affects the degree of success plaintiff obtained in the action, and the issue of attorneys' fees is remanded for further proceedings.
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