Shaunta Hudson v. United Systems of Arkansas
2013 U.S. App. LEXIS 4622
| 8th Cir. | 2013Background
- Hudson, an African American woman, worked for United Systems from 2003 to 2009, ultimately as controller, one of four executives and the only woman among them.
- She disclosed a chronic medical condition related to a pelvic mass requiring periodic drainage surgeries and brief medical leaves.
- May–June 2009 surgery complications extended leave; she returned with reduced hours after infection, then was absent June 1–4, 2009.
- Upon her return, Petkovsek confronted her, told her to sit, then told her to get out and she left; building access was denied the next day.
- Petkovsek offered a reduced-hours position if she stayed; she declined; she filed EEOC charge alleging sex and disability discrimination; jury awarded about $179,362 including $100,000 for mental anguish.
- District court denied motions for judgment as a matter of law and remittitur; United Systems appealed on the JMOL and remittitur grounds.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether denial of JMOL on sex discrimination was proper | Hudson showed intentional sex discrimination. | Petkovsek's reasons (cell phone policy, insubordination) were legitimate, nondiscriminatory. | JMOL not warranted; substantial evidence supported discrimination finding. |
| Whether JMOL on disability claim was necessary | Evidence supported discrimination on disability grounds. | Disposition moot after affirming sex claim; separate JMOL not needed. | Not necessary to address disability JMOL; sex claim affirmed. |
| Whether remittitur of mental anguish damages was proper | Award reflected legitimate mental anguish damages. | Damages were excessive and shocking. | Remittitur not warranted; district court did not abuse discretion. |
Key Cases Cited
- Conseco Fin. Serv. Corp. v. N. Am. Mortg. Co., 381 F.3d 811 (8th Cir. 2004) (trust in reviewing JMOL; indirect evidence framework)
- Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (U.S. 2000) (clear directive on evaluating witness credibility and JMOL standard)
- St. Mary's Honor Ctr. v. Hicks, 509 U.S. 502 (U.S. 1993) (Burden-shifting framework in discrimination cases; ultimate issue of discrimination)
- Ryther v. Kare 11, 108 F.3d 832 (8th Cir. 1997) (controller of evidence burden post–prima facie case)
- Burdine v. Tex. Dept. of Cmty. Affairs, 450 U.S. 248 (U.S. 1981) (established framework for discriminatory intent after prima facie case)
- Eich v. Bd. of Regents for Cent. Mo. State Univ., 350 F.3d 752 (8th Cir. 2003) (guidance on remittitur and high damages awards)
- Forshee v. Waterloo Indus., Inc., 178 F.3d 527 (8th Cir. 1999) (emotional-distress damages submission vs. remittitur focus)