Bryant v. Jeffrey Sand Co.
United States Court of Appeals for the Eighth Circuit
919 F.3d 520 (2019)
- Written by Jamie Milne, JD
Facts
Adrian Bryant (plaintiff) worked for Jeffrey Sand Company (Sand) (defendant). Bryant sued Sand under 42 U.S.C. § 1981 for racial discrimination creating a hostile work environment. Bryant presented evidence that his direct supervisor, Jerry Skaggs, routinely taunted him with racially motivated slurs and derogatory comments. Skaggs would also try to physically push Bryant around. Although Bryant reported Skaggs’s conduct to Sand, Sand did nothing to address it, even after another employee corroborated Bryant’s complaints. A jury held in Bryant’s favor. The jury awarded Bryant only nominal compensatory damages because the actual economic harm Bryant had incurred was minimal. However, the jury awarded Bryant $250,000 in punitive damages. Sand appealed the punitive-damages award, arguing that it was so excessive that it violated Sand’s due-process rights.
Rule of Law
Issue
Holding and Reasoning (Kelly, J.)
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