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Sooroojballie v. Port Authority of New York

816 F. App’x 536 (2020)

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Sooroojballie v. Port Authority of New York

United States Court of Appeals for the Second Circuit

816 F. App’x 536 (2020)

Facts

Sooroojballie (plaintiff) worked at the Port Authority of New York and New Jersey (the port authority) (defendant) under his supervisor, Gary Frattali (defendant). After resigning from the port authority, Sooroojballie filed a racial-harassment lawsuit against the port authority and Frattali in federal district court. Sooroojballie testified about three separate instances in which Frattali directed racially discriminatory remarks at Sooroojballie. Sooroojballie testified that Frattali also participated in other harassment, including falsely accusing Sooroojballie of sabotaging a port authority boiler. Sooroojballie testified that the stress caused by the hostile work environment at the port authority led to him receiving medical treatment for insomnia, anxiety, and depression. Sooroojballie attended therapy while employed at the port authority and testified that he also attended several sessions immediately after he resigned from the port authority. No evidence was presented to suggest that Sooroojballie experienced any long-term psychological or physical harm resulting from his employment at the port authority or that Sooroojballie received any further medical care related to his employment after beginning his next job. The jury awarded Sooroojballie over $2 million in compensatory damages for emotional distress against the port authority and Frattali and awarded $150,000 in punitive damages against Frattali individually. The port authority and Frattali appealed, arguing that the damages for emotional distress were excessive. Frattali also argued that the punitive-damages award was excessive.

Rule of Law

Issue

Holding and Reasoning (Per curiam)

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