Punitive Damages Award Was Not Constitutionally Excessive
The Equal Employment Opportunity Commission (“EEOC”) sued FedEx on behalf of former FedEx package handler Ronald Lockhart. The trial court awarded Lockhart, who is disabled due to deafness, the sums of $8,000 in compensatory damages and $100,000 in punitive damages, premised on a jury finding against FedEx for failing to reasonably accommodate Lockhart under the Americans with Disabilities Act (“ADA”).
In its appeal of the punitive damage award, FedEx maintained that there was insufficient evidence on which to submit the question of punitive damages to the jury, and that the punitive damages award was constitutionally excessive. The 4th Circuit rejected those contentions and affirmed the judgment, holding that: (1) sufficient evidence existed to support a finding that FedEx failed to engage in good-faith efforts to implement its ADA compliance policy; (2) the evidence was sufficient to support a finding that FedEx's higher management officials had acted reprehensibly, supporting the constitutionality of a punitive damages award; and (3) the 12.5 to 1 ratio between the compensatory and punitive damages awards did not, as a matter of law, render the punitive damages award unconstitutionally excessive.
EEOC v. Federal Express
The 4th Circuit Court of Appeals’ jurisdiction includes Maryland, North Carolina, South Carolina, Virginia and West Virginia.