United States v. Louis Rupp, II, No. 22-1444 (8th Cir. 2023)
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Defendant is a landlord, who allegedly terminated a lease based on Tenants' family status. The United States brought a claim against Defendant under the Fair Housing Act (FHA). A jury awarded Tenants $14,400 in compensatory damages and $60,000 in punitive damages. Defendant landlord filed post-trial motions, which were denied.
Defendant appealed, and the Eighth Circuit affirmed, finding that there was sufficient evidence that Defendant landlord acted with at least reckless indifference and the district court did not err in submitting the punitive damages issue to the jury. The Eighth Circuit also held that the award was not unconstitutionally excessive
Court Description: [Kelly, Author, with Erickson and Stras, Circuit Judges] Civil case - Fair Housing Act. After the district court found that Rupp had violated the Act by terminating the renters' lease based on their family status, a jury awarded them $14,400 in compensatory damages and $60,000 in punitive damages. Rupp filed a post-trial motion to set aside or reduce the punitive damages award, which the district court denied. Rupp appeals the denial of the motion. Held: There was sufficient evidence that Rupp acted with at least reckless indifference, and the district court did not err in submitting the punitive damages issue to the jury; the award was not unconstitutionally excessive. Judge Stras, concurring.
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