Bryant v. Jeffrey Sand Co., No. 18-2297 (8th Cir. 2019)Annotate this Case
Where 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.