Sharon Sanders v. Lee County School Dist. No. 1, 669 F.3d 888

Sanders, a Caucasian, served as finance coordinator for Lee County School District No. 1 from 2000 to November 2007, while most district employees were African American.
In September 2007, Board composition shifted to a racial majority; within two months four African American board members reassigned Sanders and Wayne Thompson (the other Caucasian administrator) to diminished roles, removing Thompson as superintendent and demoting Sanders to food services assistant.
Reassignments were made without consulting the employee manuals, the superintendent, or legal counsel regarding propriety.
Within five months, the Board moved to eliminate Sanders’ new position; the motion failed after a Board member withdrew her second.
Sanders, on sick leave after demotion, repeatedly sought a job description and a new contract; the Board failed to provide a description or contract, and eventually Sanders resigned on September 2, 2008, and filed suit alleging Title VII race discrimination, hostile work environment (dismissed), and constructive discharge; the jury awarded compensatory, wage/benefit, and punitive damages against individual board members.
The district court vacated Sanders’ constructive discharge and punitive damages awards and reduced her requested attorney fees; Sanders appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Constructive discharge viability	Sanders argues the Board’s demotion and inaction rendered working conditions intolerable and forced resignation.	Board contends the offer of a new position and absence of ongoing abuse negate intolerable conditions.	Rule 50 reversal; evidence supports constructive discharge.
Punitive damages viability	Sanders contends there was sufficient evidence of malice/reckless indifference to justify punitive damages.	Board argues no instruction on knowing violation or ignorance defense negates punitive liability.	Rule 50 vacatur reversed; remand for punitive-damages proof with potential ignorance defense.
Attorney-fee award framework	Contingent-fee-based award should reflect substantial success and lodestar method supports greater recovery.	District court properly reduced fees based on limited success and contingency arrangement.	Remand for fee proceedings consistent with lodestar analysis; no need to decide on method now.

Alvarez v. Des Moines Bolt Supply, Inc., 626 F.3d 410 (8th Cir. 2010) (constructive-discharge standard and evidence review)
Parrish v. Immanuel Med. Ctr., 92 F.3d 727 (8th Cir. 1996) (demotion can support constructive discharge)
Kimzey v. Wal-Mart Stores, Inc., 107 F.3d 568 (8th Cir. 1997) (new position may not shield from liability)
Green v. Harvard Vanguard Med. Assocs., Inc., 944 N.E.2d 184 (Mass. App. Ct. 2011) (intolerability can arise from adverse placement)
Fletcher v. Price Chopper Foods of Trumann, Inc., 220 F.3d 871 (8th Cir. 2000) (evidence and deference in constructive-discharge review)
Wilson v. Brinker Int'l, Inc., 382 F.3d 765 (8th Cir. 2004) (standard of review for Rule 50 judgments)
Kolstad v. Am. Dental Ass'n, 527 U.S. 526 (Supreme Court 1999) (knowledge of violations necessary for punitive damages)
Alexander v. Riga, 208 F.3d 419 (3d Cir. 2000) (presumed knowledge of illegality in discrimination cases)
Quigley v. Winter, 598 F.3d 938 (8th Cir. 2010) (lodestar framework for civil-rights fees required)
Ross v. Douglas Cnty., Neb., 244 F.3d 620 (8th Cir. 2001) (prevailing plaintiff entitled to fees under contingency or lodestar)