Estate of Barbara L. Reynolds v. Lynn Martin, Secretary of Labor

The Secretary of Labor appeals the district court’s award of pre- and post-judgment interest on damages awarded to Barbara Reynolds in her wrongful discharge suit under the Rehabilitation Act. We hold that the Civil Rights Act of 1991 entitles Reynolds to pre- and postjudgment interest on her award. Thus, we affirm. BACKGROUND

Plaintiff-appellee Barbara Reynolds was an employee of the Department of Labor from July 1, 1979 until September 26, 1980, when she was discharged. After exhausting administrative remedies, Reynolds sued the Secretary of Labor in the district court, alleging violations of the Rehabilitation Act of 1973, as amended, 29 U.S.C. § 701 et seq., the Civil Service Reform Act, 5 U.S.C. § 1201 et seq., and breach of contract. The district court granted summary judgment for the Secretary. Reynolds appealed, solely with regard to her Rehabilitation Act claim. On appeal, we reversed and remanded the case for trial. See Reynolds v. Brock, 815 F.2d 571 (9th Cir.1987).

Reynolds died while the case was pending on remand. The administrator of Reynolds’ estate was substituted for her as plaintiff. The parties consented to trial before a magistrate without a jury. The court…