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Turley v. ISG Lackawanna, Inc.
United States Court of Appeals for the Second Circuit
774 F.3d 140 (2014)
Facts
Elijah Turley (plaintiff) worked at a steel plant owned by ISG Lackawanna, Inc. (defendant). After Turley filed a grievance against a coworker, he suffered several years of extreme racial harassment and abuse at work. Turley complained to his managers and supervisors, including Larry Sampsell (defendant), the plant’s head of security, but the harassment did not stop. Sampsell witnessed much of the abuse firsthand, but he did not intervene. Instead, Sampsell blocked other supervisors’ attempts to investigate and, on several occasions, appeared to encourage Turley’s abusers. Due to the harassment, Turley was hospitalized and diagnosed with posttraumatic stress disorder, depression, and panic disorder. Turley brought a statutory-harassment claim and a claim for intentional infliction of emotional distress against his coworkers, Lackawanna, Sampsell, and other supervisors. A jury found Lackawanna and Sampsell liable under both claims and awarded Turley a total of $1,320,000 in compensatory damages. Lackawanna and Sampsell appealed, arguing that the evidence did not support the jury’s finding of liability and that the damages award was excessive.
Rule of Law
Issue
Holding and Reasoning (Sack, J.)
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