U.S. First Circuit - The FindLaw 1st Circuit Court of Appeals News and Information Blog

Jury Verdict For Plaintiff on Title VII Claim Vacated

In Morales-Vallellanes v. Potter, No. 08-2346, the First Circuit faced a challenge to a jury's $500,000 verdict in plaintiff's favor, later reduced to $300,00 due to a statutory cap and an award of $64,504 in back pay, in plaintiff's Title VII suit against his former employer, the United States Postmaster General, alleging discrimination and retaliation. 

Here, in finding that none of the claims made by plaintiff had a material effect on his employment, and therefore cannot constitute discrimination, the court vacated the jury's verdict as plaintiff failed to prove that he suffered any material adverse employment action within the meaning of Title VII's discrimination or retaliation provisions.     

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