Maria N. Gracia v. SigmaTron International, Inc.
2016 U.S. App. LEXIS 21304
7th Cir.2016Background
- Maria Gracia, a long‑term, highly regarded SigmaTron assembly supervisor, complained in October 2008 to HR (Miedema) and management (Greg Fairhead) that her manager Patrick Silverman had sent her sexually explicit/unwelcome emails and made unwanted advances. She later filed an EEOC charge.
- SigmaTron conducted a brief internal response: Fairhead met with Gracia and Silverman, effectively minimized her complaint, and required a handshake; Silverman was not disciplined.
- Two weeks after SigmaTron received Gracia’s EEOC charge, Fairhead terminated Gracia, citing a purported incident in which she allowed an employee to use the wrong solder on a customer order. The company’s memo attributed the report to another supervisor (Trujillo) and to Silverman’s intervention.
- At trial Trujillo and Gracia testified they handled the solder issue appropriately and denied reporting misconduct to Silverman; company witnesses (Silverman, Fairhead, Miedema) offered a contrary account. The jury credited Gracia on retaliation but found for SigmaTron on the sexual‑harassment claim.
- The jury awarded $57,000 compensatory and $250,000 punitive damages; statutory cap reduced compensatory to $50,000 and total to $300,000. SigmaTron appealed, challenging liability and the damages.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for Title VII retaliation | Gracia: she engaged in protected activity (complaint and EEOC charge); termination occurred shortly after; employer’s stated reason was pretextual. | SigmaTron: discharged for legitimate, non‑retaliatory reasons—tardiness and allowing wrong solder; thus no causation. | Court: Affirmed — evidence (timing, pretext, comparators) supports jury finding that but‑for cause was retaliation. |
| Employer’s proffered reasons (pretext) | Gracia: company’s explanation was false; witnesses corroborated her handling of the solder incident; similar errors didn’t lead to firing. | SigmaTron: Silverman/Trujillo reported misconduct; Fairhead relied on that report in good faith. | Court: Jury reasonably disbelieved employer witnesses and found the termination motive was retaliatory; pretext supports inference of retaliation. |
| Compensatory damages amount | Gracia: testimony about emotional distress, unemployment, and lost career prospects justified award. | SigmaTron: minimal evidence of non‑economic harm; award excessive and should be remitted. | Court: Affirmed — award not monstrously excessive, supported by plaintiff’s testimony and comparable cases; remittitur not required beyond statutory cap. |
| Punitive damages amount | Gracia: punitive award justified by employer’s malice/reckless indifference, creation of false paper trail, and concealment. | SigmaTron: conduct not sufficiently reprehensible; award excessive, biased, exceeded plaintiff’s request. | Court: Affirmed — facts as found show malice/cover‑up; 5:1 punitive:compensatory ratio acceptable within precedents and statutory cap. |
Key Cases Cited
- Empress Casino Joliet Corp. v. Balmoral Racing Club, Inc., 831 F.3d 815 (7th Cir. 2016) (standard for reviewing denial of judgment as a matter of law)
- Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (2000) (court must credit nonmovant’s evidence and may infer discrimination from employer’s pretext)
- Ripberger v. Corizon, Inc., 773 F.3d 871 (7th Cir. 2014) (elements of retaliation claim)
- Univ. of Texas Southwestern Med. Ctr. v. Nassar, 133 S. Ct. 2517 (2013) (but‑for causation standard for retaliation)
- Tullis v. Townley Eng'g & Mfg. Co., 243 F.3d 1058 (7th Cir. 2001) (non‑economic damages may rest on plaintiff’s testimony)
- AutoZone, Inc. v. EEOC, 707 F.3d 824 (7th Cir. 2013) (standards for remittitur review and evaluation of compensatory awards)
- Kolstad v. American Dental Ass'n, 527 U.S. 526 (1999) (standard for punitive damages under §1981a)
- BMW of N. Am., Inc. v. Gore, 517 U.S. 559 (1996) (guideposts for reviewing punitive damages)