U.S. Eighth Circuit - The FindLaw 8th Circuit Court of Appeals Opinion Summaries Blog

EEOC v. Siouxland Oral Maxillofacial Surgery Assoc., No. 07-2419

In an employment and sex discrimination case under Title VII, district court's judgment is reversed in part and remanded where: 1) district court erred in not submitting plaintiff's claim for punitive damages to the jury and granting defendant judgment as a matter of law on that claim as under Title VII, punitive damages are available if a plaintiff shows that the employer engaged in intentional discrimination with malice or with reckless indifference to the federally protected rights, and evidence presented by the EEOC at trial was sufficient for a jury to find that defendant acted in the face of a perceived risk that it was violating plaintiffs' Title VII rights; 2)  district court did not abuse its discretion in denying EEOC's request for injunctive relief to enjoin defendant from discriminating on the basis of pregnancy or retaliating against any employee who complains of unlawful discrimination as, in light of the two isolated instances of discrimination, there was not a consistent practice of discrimination suggesting further discrimination was likely;  3) court declined to address the district court's award of attorney's fees at this time as further proceedings are necessary on the issue of punitive damages.     

Read EEOC v. Siouxland Oral Maxillofacial Surgery Assoc., No. 07-2419

Appellate Information

Submitted: March 12, 2009

Filed: August 27, 2009

Judges

Opinion by Colloton, Circuit Judge