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Donlin v. Philips Lighting North America Corp.
United States Court of Appeals for the Third Circuit
581 F.3d 73 (2009)
Colleen Donlin (plaintiff) filed an employment-discrimination action against Philips Lighting North America Corporation (Philips) (defendant) in federal district court. Following a verdict in Donlin’s favor, the jury awarded Donlin $395,795 in front pay. The award was based on the difference between Donlin’s earnings at Philips compared with her earnings in her new employment position over a 25-year period. Although the district court allowed a front-pay award on the ground that Donlin was earning a lower salary in her new position, it modified the award to $101,800. The district court’s modification was based on the difference in earnings over a 10-year period. Despite the modification, Philips appealed. Philips argued that the district court had abused its discretion by awarding Donlin front pay because Donlin had mitigated her damages by obtaining employment. Philips also argued that the front-pay award was too speculative because Donlin’s earnings, had she remained at Philips, would have depended on market conditions. The United States Court of Appeals for the Third Circuit reviewed the case.
Rule of Law
Holding and Reasoning (Hardiman, J.)
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