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Quigley v. Winter

United States Court of Appeals for the Eighth Circuit
598 F.3d 938 (8th Cir. 2010)


Facts

Jaymie Quigley (plaintiff) and her children rented a house from Dale Winter (defendant) using a Section 8 housing voucher. Over the course of a few years, Winter made several inappropriate sexual advances toward Quigley, including touching her sexually, showing up at her house late at night and unannounced, staying longer than he was welcome after conducting inspections of the house, and making sexual comments about her 14-year-old sister. Eventually, Quigley decided to move out and asked Winter if she would get her security deposit back. In response, “Winter fluttered his hand against Quigley’s stomach and said, ‘My eagle eyes have not seen everything yet.’” Quigley brought suit for hostile housing environment created by sexual harassment, quid pro quo sexual harassment, and coercion, intimidation, and interference with housing rights, among other things. The jury found in favor of Quigley on all claims and awarded her over $13,685 in compensatory damages. The jury also awarded $250,000 in punitive damages. On Winter’s motion, the district court reduced the punitive damages award to $20,527.50, or one and a half times the compensatory damages. Winter appealed.

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Holding and Reasoning (Riley, J.)

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