Turley v. ISG Lackawanna, Inc.
960 F. Supp. 2d 425
W.D.N.Y.2013Background
- Elijah Turley, an African-American steelworker in Lackawanna, experienced years of racial harassment at the plant from 2003–2007.
- Lackawanna’s supervisors allegedly created or permitted a hostile environment, including offensive graffiti, threats, and demeaning conduct.
- Defendants include Lackawanna, its parent AM USA, and individual supervisors Sampsell, Marchand, and Jaworski; Lackawanna’s parent had centralized control elements.
- The jury found a hostile environment and intentional infliction of emotional distress, and awarded over $25 million in damages (compensatory and punitive).
- Defendants moved for judgment as a matter of law or new trial; Turley moved for attorney fees.
- Court denied most relief but reduced punitive damages and granted attorney-fee recovery with limitations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Single-employer liability under Title VII/§1981 | Turley proved AM USA and Lackawanna shared control | AM USA acted independently; no centralized control | Jurors could find single-employer status; liability upheld |
| Liability under Title VII, §1981, and NYHRL | Defendants failed to remedy harassment; liable | Remedial actions were adequate; liability limited | Evidence supported corporate and individual liability under all three statutes |
| Intentional infliction of emotional distress & punitive damages | Sampsell’s conduct was extreme; warrant punitive damages | Conduct not within scope or sufficiently extreme | Liability for IIED upheld; punitive damages reduced to satisfy due-process limits |
| Verdict form/jury charge errors & passion/prejudice | No prejudicial errors; verdict reflects damages | Charges were flawed; potential prejudice | No reversible error found; damages adjusted via remittitur guidance |
| Damages and attorney-fees awards | Damages and fees reasonable given conduct | Awards were excessive or misallocated | Punitive damages reduced to $5 million; attorney-fee award approved with reductions |
Key Cases Cited
- Galdieri-Ambrosini v. Nat’l Realty & Dev. Corp., 136 F.3d 276 (2d Cir.1998) (standard for judgment as a matter of law; deference to jury credibility)
- State Farm Mut. Auto. Ins. Co. v. Campbell, 538 U.S. 408 (U.S. 2003) (guideposts for punitive-damages review; reprehensibility, ratio, sanctions)
- Burlington Indus., Inc. v. Ellerth, 524 U.S. 742 (U.S. 1998) (supervisor harassment generally not within scope of employment; exceptions apply)
- Payne v. Jones, 696 F.3d 189 (2d Cir.2012) (remittitur standard and less-than-grossly-excessive review of punitive awards)
- Murray v. Miner, 74 F.3d 402 (2d Cir.1996) (single-employer doctrine rationale and shared decisionmaking)