United States District Court, Middle District of Louisiana
EDWINA F. FIELDS
DEPARTMENT OF PUBLIC SAFETY ELAYN HUNT CORRECTIONAL CENTER
RULING AND ORDER
JOHN W. deGRAVELLES, JUDGE.
This matter came before the Court on the Motion to Vacate Jury Award of Compensatory and Punitive Damages, or in the Alternative, Motion for New Trial on Limited Issue of Damages or Remittitur (R.Doc. 135) and the Motion to Request Judicial Notice of Prior Ruling on Motion to Dismiss (R.Doc. 146), both of which were filed by the Defendant, State of Louisiana, Department of Public Safety and Corrections. Plaintiff Edwina Fields opposes the motions. (R.Docs. 136 & 149).
Having carefully considered the law, facts, and arguments of the parties, the Court grants the Defendants’ motions. The jury awards of compensatory and punitive damages are vacated, and the Court will enter a judgment finding that the Defendant is not liable to the Plaintiff for any damages.
I. Factual and Procedural Background
Plaintiff, an African-America female, brought suit under Title VII alleging that she was discriminated against by the Defendant on the basis of her sex and race. Plaintiff was employed by the Defendant as a guard at Elayn Hunt Correctional Center.
On November 27, 2012, this Court granted in part Defendant’s motion to dismiss. (See R.Doc. 21 & Fields v. Department of Public Safety, 911 F.Supp.2d 373 (M.D.La. 2012)). In that ruling, the Court dismissed, among other claims, the Plaintiff’s claim for punitive damages under Title VII. The Court explained:
[Title VII] precludes plaintiffs from recovering punitive damages against governments, government agencies, and political subdivisions:
A complaining party may recover punitive damages under this section against a respondent (other than a government, government agency or political subdivision) if the complaining party demonstrates that the respondent engaged in a discriminatory practice or discriminatory practices with malice or with reckless indifference to the federally protected rights of an aggrieved individual.
42 U.S.C. § 1981a(b) (emphasis added). Therefore, Plaintiffs claims for punitive damages under the ADA and Title VII are dismissed.
Fields, 911 F.Supp.2d at 386.
Later, the Defendant filed a motion for summary judgment (R.Doc. 47), and the Court granted in part Defendant’s motion. (See R.Doc. 82 & Fields v. Department of Public Safety, No. 11-101, 2014 WL 5801460 (M.D.La. Nov. 6, 2014)). After this ruling, Plaintiff’s remaining claims consisted of (1) claims for disparate treatment for Defendant’s alleged failure to transfer her to the 24-hour Unit Ward and failure to transfer her out of the HSU and D1 Cellblocks, and (2) claims for a hostile work environment for Lt. Col. Jackson allegedly moving her desk so that a prisoner could more easily masturbate, for the officers’ alleged request to stop writing Rule 21 violations, and for being exposed generally to watching inmates masturbate and having them do so on her. These remaining issues were tried on December 1 through 4, 2014.
On the jury verdict form (R.Doc. 131), the jury found that the Defendant was not liable on Plaintiff’s disparate treatment claim. Specifically, while the jury found that the Plaintiff suffered an “adverse employment decision” when the Defendant denied her a transfer to the 24 Hour Unit or denied her a transfer out of the HSU and D1 Cell Blocks (See Interrogatory No. 1) and that the Plaintiff proved that the assignment she requested was “objectively better” than her existing assignment (See Interrogatory No. 2), the jury found that the Plaintiff failed to prove that she applied for and was qualified for a position for which the Defendant was seeking applicants (See Interrogatory No. 3), as required for a finding of liability under McDonnel Douglas Corp. v. Green, 411 U.S. 792, 802, 93 S.Ct. 1817, 1824 (1973). After answering this question, the jury correctly followed the instructions and skipped the remaining questions related to the disparate treatment claim.
The jury also found no liability on the Plaintiff’s sexual harassment claim. Specifically, the jury found that Plaintiff failed to prove that she was sexually harassed by her supervisor Lt. Col. Jackson by his alleged repositioning of the desk (See Interrogatory No. 10) and that the Plaintiff failed to prove that she was sexually harassed by her supervisors Lt. Donald Johnson and/or Captain Childs by their alleged instructions to the Plaintiff to no longer write up Rule 21 violations. (See Interrogatory No. 11). While the jury found that Fields was harassed by prisoner inmates because of her sex (See Interrogatory No. 12) and that the Defendant knew or should have known about the harassment (See Interrogatory No. 13), the jury found that the Defendant did not encourage, endorse, or instigate the inmates’ harassing requirement, as required for a finding of liability. See Fields, 2014 WL 5801460, at *9-*10. Thus, the jury found that the Defendants committed no Title VII violations.
Despite the finding of no liability, the jury awarded $120, 000.00 in compensatory damages (See Interrogatory No. 16). Further, even though the Court previously dismissed the Plaintiff’s claim for punitive damages, the issue was inadvertently submitted to the jury without objection from the parties. Although the jury found no liability on the Title VII claims, they also found that the Defendant “acted with malice or reckless disregard to Plaintiff[’s] … rights” (See Interrogatory No. 19), found that ...