Jill Lansdale v. Hi-Health Supermart Corporation, Jill Lansdale v. Hi-Health Supermart Corporation

Jill Lansdale obtained a verdict against Hi-Health Supermart Corp. for gender discrimination. See 42 U.S.C. § 2000e-2(a) (Title VII). She appeals the limitation of her damages pursuant to 42 U.S.C. § 1981a and asserts that the statute is unconstitutional. We affirm.

BACKGROUND

After she was terminated from Hi-Health, Lansdale brought this action and claimed that Hi-Health, through its owner and president, discriminated against her by establishing a hostile environment based upon her gender. The jury agreed and awarded damages of $100,000 for pain and suffering, mental anguish, shock and discomfort, plus $1,000,000 in punitive damages.

The district court then applied the limitation in 42 U.S.C. § 1981a and reduced the damage award to $200,000. Lansdale claims that the statutory limitation is unconstitutional and, therefore, appeals from the district court’s reduction of the jury award.

STANDARD OF REVIEW

We review the constitutionality of the statute limiting damages de novo. See Gray v. First Winthrop Corp., 989 F.2d 1564, 1567 (9th Cir.1993). We would only invalidate the statute for “the most compelling constitutional reasons.” Id. (internal quotation marks and…