Sharon Black v. City and County of Honolulu

MEMORANDUM AND ORDER

The City and County of Honolulu (the “City”) appeals from the district court’s entry of judgment in favor of Sharon Black based on a jury verdict in Black’s favor on her claim of retaliation under Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e-3(a). The City objects to both the judgment and the district court’s award of attorney’s fees for Black’s trial counsel, Mark Beatty. Beatty, as interve-nor, argues that the district court erred in denying attorney’s fees for some of his work. We affirm both the judgment and the grant of attorney’s fees.

1. The City claims that neither the jury’s verdict nor the denial of the City’s motion for judgment as a matter of law can be affirmed because there was not substantial evidence of either (1) the existence of an adverse employment action, or (2)a causal link between Black’s protected activity and any adverse employment action. See Stegall v. Citadel Broad. Co., 350 F.3d 1061, 1065-66 (9th Cir.2004) (describing the elements of a prima facie Title VII retaliation case); Gilbrook v. City of Westminster, 177 F.3d 839, 856 (9th Cir.1999) (stating that “substantial evidence” is the appropriate standard of…