Joyce v. Town of Dennis
770 F. Supp. 2d 424
D. Mass.2011Background
- Joyce sued the Town of Dennis, two Town-owned golf courses, and individual defendants for gender discrimination.
- In May 2007, a men-only tournament excluded Joyce from playing while allowing a male partner instead.
- Defendants’ initial decision against Joyce was reviewed by Town administration, who did not find a discriminatory practice at that time.
- The Golf Advisory Committee (GAC) reconsidered gender-based rules and, by mid-2007, proposed changes for 2008 and beyond.
- The GAC later approved allowing women in men’s tournaments and October 2007 the policy change was formally adopted for future events.
- Joyce filed suit (Feb 2008); by March 2010 the court found liability on several counts and damages remained to be determined.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Attorney's fees entitlement under statute | Joyce seeks fees under M.G.L. ch. 151B and 42 U.S.C. § 1988 | Defendants oppose fees as inappropriate in this context | Fees awarded under both statutes. |
| Punitive damages availability | Joyce argues punitive damages may be warranted for discriminatory conduct | Defendants contend no evil motive or risk awareness; no punitive instruction warranted | Jury instruction on punitive damages precluded. |
Key Cases Cited
- Farrar v. Hobby, 506 U.S. 103 (U.S. 1992) (appropriate considerations for fee-shifting awards; degree of success matters)
- Hensley v. Eckerhart, 461 U.S. 424 (U.S. 1983) (reasonable attorney's fees depend on scope of success)
- Smith v. Wade, 461 U.S. 30 (U.S. 1983) (standards for punitive damages in civil rights cases)
- Kolstad v. American Dental Ass'n, 527 U.S. 526 (U.S. 1999) (intent and awareness required for punitive damages)
- Iacobucci v. Boulter, 193 F.3d 14 (1st Cir. 1999) (circumstantial proof of discriminatory intent permissible)
- Barzingus v. Wilheim, 306 F.3d 17 (10th Cir. 2010) (notations on summary judgment standards for related issues)
- Clark v. Arizona Interscholastic Ass'n, 695 F.2d 1126 (9th Cir. 1982) (sports gender segregation may be justifiable)
- Barnett v. Texas Wrestling Ass'n, 16 F.Supp.2d 690 (N.D. Tex. 1998) (context of gender discrimination in sports rules)
- Borne v. Haverhill Golf & Country Club, Inc., 58 Mass.App.Ct. 306, 791 N.E.2d 903 (Mass. App. Ct. 2003) (distinguishable punitive damages in discriminatory policies)
- Dichner v. Liberty Travel, 141 F.3d 24 (1st Cir. 1998) (punitive damages standards in §1983 actions)
- Trinh v. Gentle Commc'ns, LLC, 71 Mass.App.Ct. 368, 881 N.E.2d 1177 (Mass. App. Ct. 2008) (punitive damages standards in Massachusetts appellate context)