Huyett v. v. Doug's Family Pharmacy
160 A.3d 221
| Pa. Super. Ct. | 2017Background
- Huyett, a pharmacy technician, was fired shortly after informing her employer she had been diagnosed with Hodgkin’s lymphoma; she sued under the PHRA for disability discrimination and won a jury verdict awarding full economic losses and $2,500 in non‑economic damages.
- Huyett sought $106,429.30 in attorney fees under 43 P.S. § 962(c.2) (PHRA). The trial court denied fees, finding the evidence of a PHRA violation weak and questioning a key witness’s credibility.
- On initial appeal the Superior Court vacated and remanded, instructing the trial court to apply the correct legal standard (Hoy v. Angelone) when deciding whether to award fees; the Supreme Court denied allowance of appeal.
- On remand the trial court reweighed the trial transcript, again concluded the violation was "fairly debatable" and "weak," and denied attorney fees; Huyett appealed.
- The Superior Court affirmed, holding that under the PHRA the award of fees is discretionary and the trial court may independently weigh the evidence of a violation when deciding whether to award fees.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial court erred on remand by denying attorney fees after a jury verdict for Huyett | Huyett: prevailing plaintiff entitled to fees; trial court improperly reweighed jury credibility and essentially overruled the verdict | Pharmacy: PHRA §962(c.2) gives trial court discretion to award fees and to assess whether a violation occurred | Held: Fee award is discretionary; trial court may reweigh evidence of violation when deciding fees and did not abuse discretion |
| Whether PHRA’s remedial purpose mandates or presumptively requires fee awards | Huyett: PHRA is remedial; fees are an affirmative remedy and effectively mandatory to make plaintiff whole | Pharmacy: Remedial purpose does not override statute’s clear “may” language granting discretion | Held: PHRA’s text controls; §962(c.2) uses “may,” so fees are not mandatory or presumptive; discretion remains with trial court |
| Whether denial of fees was inconsistent with denial of JNOV | Huyett: if evidence legally supported the verdict, trial court could not later find no violation for fee purposes | Pharmacy: JNOV standard (viewing evidence favorable to verdict winner) differs from fee‑award inquiry, which allows the court to reweigh evidence | Held: Different standards apply; denying JNOV and denying fees are not inconsistent because fee decision is an independent discretionary weighing of evidence |
Key Cases Cited
- Hoy v. Angelone, 720 A.2d 745 (Pa. 1998) (fee provision in PHRA is discretionary; trial court may deny fees after weighing evidence)
- Samuel‑Bassett v. Kia Motors Am., Inc., 34 A.3d 1 (Pa. 2011) (standards for statutory interpretation; plenary review for statutory questions)
- Krebs v. United Ref. Co., 893 A.2d 776 (Pa. Super. 2006) (fee awards under remedial statutes must be consistent with legislative purpose)
- Wagner v. Pa. Capitol Police Dep’t, 132 A.3d 1051 (Pa. Commw. Ct. 2016) (no presumption of fee award under PHRA; trial court’s discretion upheld)
- Logan v. Marks, 704 A.2d 671 (Pa. Super. 1997) (distinguishing fee statutes; federal presumption for civil‑rights fee awards not controlling here)
- Newman v. Piggie Park Enterprises, 390 U.S. 400 (1969) (federal rule awarding fees to prevailing civil‑rights plaintiffs—discussed and distinguished)