Bryant v. Jeffrey Sand Co., No. 18-2297 (8th Cir. 2019)
Annotate this CaseWhere a jury awarded plaintiff nominal compensatory damages and punitive damages for his claim of hostile work environment against his former employer, the Eighth Circuit affirmed the district court's denial of defendant's post-trial motions and grant of attorney's fees to plaintiff. The court held that the $250,000 award of punitive damages was supported by the record where plaintiff repeatedly complained to supervisors that his manager was using racial slurs and the company did not take action; plaintiff's 42 U.S.C. 1981 claim was timely under the applicable four year statue of limitations where the workplace abuse continued into the limitations period; the punitive damages amount was constitutionally sound in light of the degree of reprehensibility of defendant's misconduct; and the district court did not abuse its discretion in awarding attorney's fees and accepting the attorney's hourly rate as reasonable.
Court Description: Kelly, Author, with Benton and Melloy, Circuit Judges] Civil Case - racial hostile work environment. On appeal from jury verdict for nominal compensatory and punitive damages, the award of punitive damages is supported by the record, as the jury could have reasonably concluded that Jeffrey Sand exhibited reckless indifference to Bryant's rights; the claims under 42 U.S.C. sec. 1981 were timely under the four-year statute of limitations, as the continuing violation rule applies to punitive and compensatory damages and one act occurred within the statutory period; award of $250,000 in punitive damages does not violate due process as excessive or disproportionate in light of the degree of reprehensibility of Jeffrey Sand's conduct, the indignities suffered even as compared to the small amount of economic damages, and lack of a statutory cap under section 1981. The district court did not abused its discretion in awarding attorneys fees based on a lodestar rate of $350 per hour.
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.