Joyce v. Town of Dennis, MA
2013 U.S. App. LEXIS 12199
| 1st Cir. | 2013Background
- Joyce, a golfer, sought to play in a Dennis Pines men's tournament in 2007 but was barred due to gender; the GAC and Town officials changed policy multiple times leading to a 2008 policy allowing women to play with men; Joyce filed federal and state discrimination claims against the Town, golf courses, and officials; the district court found liability for discrimination but limited relief; damages were tried in 2011 with a $15,000 compensatory award and modest attorney's fees awarded; the district court denied injunctive relief and reduced fees, prompting appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Punitive damages instruction proper? | Joyce seeks punitive damages for state-law discrimination. | Defendants contend punitive damages are inappropriate given the conduct and changes in policy. | No error: punitive-damages instruction properly denied. |
| Injunctive relief appropriate? | District court should grant an injunction requiring gender-neutral policies and training. | Policy changes already implemented and no ongoing irreparable harm shown. | Remand for four-factor injunctive-relief analysis with explanation. |
| Attorney's fees calculation proper? | Fees should reflect broad success and public interest; not limited by damages alone or settlement rejection. | Fees should be limited by damages and settlement posture. | Remand to recompute fees; error in tying fees to damages and penalizing settlement rejection. |
| Prevailing party for fees and special circumstances? | Joyce prevailed on federal/state claims and is entitled to fees. | Special-circumstances clause may bar fees due to conduct and settlement factors. | Joyce entitled to reasonable fees but remanded for recalculation; no punitive-fee bar. |
Key Cases Cited
- Haddad v. Wal-Mart Stores, Inc., 914 N.E.2d 59 (Mass. 2009) (punitive-damages standard in discrimination cases; egregious conduct not required for all cases)
- City of Riverside v. Rivera, 477 U.S. 561 (1986) (fee awards under §9 reflect public interest beyond damages; not proportional to damages)
- Coutin v. Young & Rubicam P.R., Inc., 124 F.3d 331 (1st Cir. 1997) (fee-shifting: results obtained are multi-faceted and not limited to damages)
- Farrar v. Hobby, 506 U.S. 103 (1992) (importance of results in determining fees; nominal relief impact)
- Hensley v. Eckerhart, 461 U.S. 424 (1983) (multifactor approach to calculating reasonable fees; results matter)
- Stratos v. Dep't of Pub. Welfare, 439 N.E.2d 778 (Mass. 1982) (lodestar method; reasonable hours/rates; adjustment factors)