Equal Employment Opportunity Commission v. Wal-Mart Stores Inc.

A jury returned a verdict in favor of appellant Equal Employment Opportunity Commission (EEOC), finding that Wal-Mart Stores, Inc. (Wal-Mart) intentionally discriminated against a job applicant, Jamey Stern (Stern), based on her pregnancy, in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e et seq. Prior to trial, the district court denied Wal-Mart’s motion for partial summary judgment on the issue of punitive damages. After a trial on the merits, the jury awarded Stern back pay; however, the district court refused the EEOC’s request for an instruction to the jury on the issue of punitive damages, ruling that 42 U.S.C. § 1981a(b)(l) requires a heightened standard of proof to sustain a punitive damages claim under Title VII.

The EEOC now appeals the district court’s refusal to submit the issue of punitive damages to the jury. We have jurisdiction pursuant to 28 U.S.C. § 1291 , and we reverse.

FACTS AND PROCEEDINGS BELOW

Jamey Stern worked at a Wal-Mart store in Green Valley, Arizona as a clothing clerk from April 1991 through August 1991, when she resigned her position so that she could attend classes at a community college. Shortly thereafter, Stern…