AutoZone, Inc. v. Equal Employment Opportunity Commission

MEMORANDUM

AutoZone, Inc., appeals and the Equal Employment Opportunity Commission (EEOC), on behalf of claimant Stacey Wing, cross-appeals from a final judgment of the United States District Court of the District of Arizona awarding Wing, pursuant to a jury verdict, $15,000 in compensatory damages and $50,000 in punitive damages on her hostile work environment claim.

AutoZone argues that it could not be liable for the harassment Wing endured because it established at trial the El-lerth/Faragher “reasonable care” defense to vicarious liability for non-tangible employment action. See Faragher v. Boca Raton, 524 U.S. 775, 807-08 , 118 S.Ct. 2275 , 141 L.Ed.2d 662 (1998); Burlington Indus., Inc. v. Ellerth, 524 U.S. 742, 765 , 118 S.Ct. 2257 , 141 L.Ed.2d 633 (1998). It maintains that the district court erred when it denied AutoZone’s motions for judgment as a matter of law or for a new trial. See Fed.R.Civ.P. 50. AutoZone also contends that the punitive damage award was inappropriate because the corporation acted in good faith to comply with its obligations under Title VII. The EEOC urges us to uphold the district court’s determinations as to these issues but argues that the…