Robinson v. Ergo Solutions, LLC
2014 U.S. Dist. LEXIS 27049
| D.D.C. | 2014Background
- Robinson filed a Title VII harassment suit against Ergo Solutions, LLC in the D.C. District Court; Ergo defaulted by failing to answer.
- Default was entered against Ergo; Robinson moved for default judgment seeking substantial noneconomic and punitive damages.
- The court held a damages hearing; Ergo did not present witnesses or evidence.
- The court found Ergo liable for a Title VII hostile-work-environment claim based on Henderson's conduct.
- Damages awarded: $20,000 in compensatory noneconomic damages; no punitive damages awarded; statutory cap considerations discussed.
- Court noted the absence of out-of-pocket damages and limited corroborating evidence for noneconomic harms.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether default judgment establishes liability for hostile-work-environment claim | Robinson's complaint asserts all elements of Title VII harassment | (No explicit argument provided in the record) | Yes; default proves liability for Title VII claim. |
| What amount of damages is appropriate | Requests $200,000 compensatory and $200,000 punitive | (No explicit argument provided in the record) | Award $20,000 as compensatory noneconomic damages; punitive damages denied. |
| Whether punitive damages or damages cap affect the award | Punitive damages permissible under 42 U.S.C. § 1981a; cap considerations | (No explicit argument provided in the record) | Punitive damages denied; cap discussed as applying to total damages; award within cap. |
Key Cases Cited
- Meritor Savings Bank, FSB v. Vinson, 477 U.S. 57 (U.S. 1986) (hostile environment includes pervasive harassment)
- Harris v. Forklift Sys., Inc., 510 U.S. 17 (U.S. 1993) (severe or pervasive conduct alters terms and conditions of employment)
- Davis v. Coastal Intl. Sec., Inc., 275 F.3d 1119 (D.C. Cir. 2002) (elements of Title VII hostile-work-environment claim)
- Burlington Indus., Inc. v. Ellerth, 524 U.S. 742 (U.S. 1998) (employer vicarious liability for supervisor harassment)
- Faragher v. City of Boca Raton, 524 U.S. 775 (U.S. 1998) (employer liability for supervisor harassment; Faragher standard)
- Kolstad v. American Dental Ass'n, 527 U.S. 526 (U.S. 1999) (malice or reckless indifference required for punitive damages)