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Bryant v. Aiken Regional Medical Centers Inc.

333 F.3d 536 (2003)

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Bryant v. Aiken Regional Medical Centers Inc.

United States Court of Appeals for the Fourth Circuit
333 F.3d 536 (2003)

Facts

Wanda Bryant (plaintiff), a Black woman, worked as a surgical technician for Aiken Regional Medical Centers Inc. (ARMC) (defendant). Bryant sued ARMC under Title VII of the Civil Rights Act of 1964 (Title VII), alleging that she was passed over for promotion several times because of her race, violating Title VII’s prohibition against racial discrimination. A jury held in Bryant’s favor, awarding her $40,000 in backpay, $50,000 in compensatory damages, and $210,000 in punitive damages. ARMC appealed the punitive-damages award, arguing that ARMC was not vicariously liable for discriminatory decisions made by Bryant’s manager because any such decisions conflicted with ARMC policies and practices. ARMC had an equal-employment-opportunity policy expressly stating that decisions regarding promotion and other advancement opportunities were to be made in a nondiscriminatory manner, without regard to race. ARMC also had a grievance policy providing a procedure for reporting discriminatory conduct and promising that employees would not face retaliation for making such reports. Additionally, ARMC had a diversity-training program for employees and voluntarily monitored department demographics to ensure diversity. The court of appeals considered ARMC’s argument regarding liability for punitive damages.

Rule of Law

Issue

Holding and Reasoning (Wilkinson, J.)

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