Parker v. Four Seasons Hotels, Ltd.
845 F.3d 807
7th Cir.2017Background
- Diane Parker was injured when a sliding glass “barn” door in her Four Seasons hotel bathroom suddenly shattered while she was using it. The hotel admitted negligence and a jury awarded $20,000 (reduced to $12,000 after set-off).
- Parker alleged the hotel knew of widespread door failures: the hotel engineer reportedly said the stopper had moved “again,” rooms had been put on a “do not sell” list, and contractor emails documented multiple prior door breakages (including Parker’s room). The district court admitted the email under the residual hearsay exception.
- Four Seasons conceded negligence; the only disputed pretrial legal question was whether Parker presented sufficient evidence to put punitive damages (wilful and wanton conduct) to the jury.
- The district court barred the punitive-damages claim as a matter of law, concluding Parker’s evidence did not meet Illinois’ wilful-and-wanton or similar standards for exemplary damages.
- Parker appealed pro se. The Seventh Circuit reviewed de novo whether summary judgment on punitive damages was proper and reversed, holding that the record—construed in Parker’s favor—permitted a reasonable jury to find wilful and wanton conduct and remanded for proceedings on punitive damages.
Issues
| Issue | Parker's Argument | Four Seasons' Argument | Held |
|---|---|---|---|
| Amount-in-controversy for diversity jurisdiction | Her complaint in good faith sought compensatory and punitive damages exceeding $150,000 at filing | The ultimate award ($12,000) shows amount did not meet $75,000 threshold | Jurisdiction satisfied because amount-in-controversy is assessed at time of filing; federal jurisdiction stands (plaintiff’s good-faith allegation accepted) |
| Sufficiency of evidence to submit punitive damages to the jury | Evidence (engineer’s statement, contractor email, prior breakage in same room, “do not sell” list) shows knowledge of ongoing danger and renting the room anyway — supports wilful and wanton conduct | Evidence may be explained by good-faith repairs or other benign inferences; hotel argued summary judgment proper to bar punitive damages | Reversed: construing in plaintiff’s favor, reasonable juror could infer wilful and wanton conduct; punitive damages claim may be presented to the jury |
| Proper standard of review for barring punitive damages pretrial | N/A (challenge to district court legal ruling) | Sought deference as evidentiary ruling (abuse of discretion) | Seventh Circuit reviewed de novo because the question was legal sufficiency for a cause of action (summary judgment standard) |
| Attorney withdrawal before trial | Parker argued abuse of discretion in permitting counsel to withdraw | Hotel did not contest; district court allowed withdrawal after impasse | No abuse of discretion: withdrawal permitted, plaintiff had ample time to proceed pro se and suffered no prejudice |
Key Cases Cited
- Rosado v. Wyman, 397 U.S. 397 (rule that jurisdictional amount is measured at filing)
- St. Paul Mercury Indemnity Co. v. Red Cab Co., 303 U.S. 283 (events after filing that reduce the amount recoverable do not divest jurisdiction)
- Mathias v. Accor Economy Lodging, Inc., 347 F.3d 672 (7th Cir. 2003) (hotel repeatedly renting rooms it had labeled ‘do not rent’ supports punitive-damage theory)
- Kelsay v. Motorola, Inc., 74 Ill.2d 172 (Ill. 1978) (standard for punitive/exemplary damages under Illinois law)