632 F. App'x 114
4th Cir.2015Background
- Eileen Hylind sued Xerox for gender discrimination and retaliation under Title VII and prevailed; the district court awarded compensatory damages and back pay.
- On prior appeal, this Court affirmed most rulings but vacated the back pay award and remanded for the district court to reconsider offsets under Sloas v. CSX.
- On remand the district court held Xerox’s disability-plan payments to Hylind were collateral-source benefits and therefore did not offset her back pay; the court recalculated interest and denied several Rule 60 motions by Hylind.
- Xerox appealed the collateral-source ruling and other calculations; Hylind cross-appealed certain interest and Rule 60 rulings and sought modification/clarification of postjudgment interest.
- The Fourth Circuit applied the mandate rule to bar relitigation of issues previously decided, affirmed the district court’s collateral-source finding and interest calculations with one modification (postjudgment interest is compound).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether mandate rule bars reconsideration of previously decided back-pay components | Hylind sought reconsideration of years/pay rate and other items | Xerox argued the mandate rule precludes relitigation | Mandate rule bars reconsideration; prior determinations stand |
| Whether Xerox’s disability-plan payments offset back pay under collateral-source rule | Hylind argued payments were employee benefits and collateral-source, not offsets | Xerox argued payments indemnified it and should offset back pay | Payments are collateral-source benefits; no offset; district court correctly applied Allen factors and Sloas framework |
| Proper start date and form of postjudgment interest on compensatory and back-pay awards | Hylind argued various corrections needed to interest dates and compound vs. simple interest | Xerox defended district court’s interest rulings, including using earlier judgment date for back-pay interest | Court upheld interest start dates; clarified that postjudgment interest is compound under §1961(b) |
| Whether Rule 60(a) permitted correction of alleged calculation errors in prejudgment interest | Hylind argued the court should correct calculations as clerical/math errors | Xerox maintained calculations were deliberate estimations, not clerical mistakes | Denial of Rule 60(a) relief affirmed; calculations were discretionary estimations, not mathematical errors |
Key Cases Cited
- Sloas v. CSX Transp., 616 F.3d 380 (4th Cir. 2010) (collateral-source rule and when employer benefits may be offset)
- Kaiser Aluminum & Chem. Corp. v. Bonjorno, 494 U.S. 827 (U.S. 1990) (postjudgment interest runs from date of judgment preserved by affirmed portions)
- United States v. Susi, 674 F.3d 278 (4th Cir. 2012) (mandate rule forecloses relitigation of issues decided on appeal)
- Allen v. Exxon Shipping Co., 639 F. Supp. 1545 (D. Me. 1986) (multi-factor test for evaluating whether an employer payment is a collateral source)
- Scoggins v. Lee’s Crossing Homeowners Ass’n, 718 F.3d 262 (4th Cir. 2013) (ripeness principles for claims resting on contingent future events)