against Defendant Fannie Mae under Title VII of the Civil Rights Act. That award has now been reduced, see Section II supra, to $ 453,500. In addition, the jury awarded a total of $ 1,901,000 against all three Defendants under the D.C. Human Rights Act. That award has now been reduced, see Section III 3, supra, to $ 1,650,000.
For the reasons already set forth, the Court concludes that there is ample evidence to support the jury's award under Title VII of $ 453,500 (comprising $ 153,500 in back pay and $ 300,000 in non-economic damages). Therefore, the Court will turn to the awards made under the D.C. Human Rights Act.
It is clear from examining the structure of the awards made by the jury under our local discrimination statute that it wished to impose very substantial punitive damages against the employer, Defendant Fannie Mae, as the ultimately responsible party, on both the harassment and retaliation claims. By refusing to award any damages against Defendant Fannie Mae for emotional pain and suffering on the harassment claim,
and by awarding a substantial amount ($ 100,000) for emotional pain and suffering and a significant, albeit lesser, amount in punitive damages against the individual who did the harassing, the jury was clearly demonstrating its recognition that Defendant Kobayashi had to be held personally accountable and punished for his gender-based harassment of Ms. Martini. The jury also made clear that by refusing to award any damages for emotional pain and suffering against Defendant Knight and by awarding a very nominal $ 1000 in punitive damages against her, that it did not find any great culpability on her part for the underlying gender-based harassment.
On the retaliation claim, the jury's analysis appears to have been quite different. From its fairly modest awards for both pain and suffering and punitive damages against Defendants Kobayashi and Knight, it is clear that while the jury recognized some culpability on their part, it found the employer, Defendant Fannie Mae, to bear the primary responsibility for allowing Ms. Martini to be re-organized out of a job because of her harassment complaints.
Given the entire record presented in this case, the Court concludes that the allocation of responsibility and amount of awards made as to Defendant Kobayashi and Defendant Knight are eminently reasonably and supported by the evidence. In particular the jury's verdict reflects its conclusion that Mr. Kobayashi's gender-based harassment of Ms. Martini inflicted substantial pain and suffering and that the punitive damages assessed against him should be 20% of those non-economic damages. As to Defendant Knight, the jury viewed her as having no responsibility for the emotional damage caused by Defendant Kobayashi's gender-based harassment and therefore, as already discussed, she is not liable for the minimal punitive damages assessed against her. Finally, the Court concludes that it was entirely reasonable for the jury to hold Defendant Knight, as Defendant Kobayashi's direct supervisor, responsible, to a modest degree, for Plaintiff's emotional pain and suffering attributable to the retaliation.
Turning to the jury's award of $ 500,000 in emotional pain and suffering and $ 1,000,000 in punitive damages against Defendant Fannie Mae on the retaliation claim, the Court does conclude that those amounts are so "inordinately large as obviously to exceed the maximum limit of a reasonable range within which the jury may properly operate", Webb, 861 F. Supp. at 1113. Given all the evidence in this case, ranging from Ms. Martini's initial humiliation and distress at being terminated to her ultimate ability to change her professional direction slightly and return to school in an allied field, the Court concludes that the award against Defendant Fannie Mae for emotional pain and suffering on the retaliation claim should be reduced to $ 100,000. In light of the jury's initial determination that the punitive damages imposed against Defendant Fannie Mae on this claim should be double the amount of damages awarded for emotional pain and suffering, the Court will remit the punitive damages to $ 200,000.
Thus, the final damage awards in this case will be as follows:
Title VII--Defendant Fannie Mae $ 453,500
D.C. Human Rights Act $ 450,000
Defendant Fannie Mae--Retaliation claim--
Emotional Pain & Suffering $ 100,000
Punitive Damages $ 200,000
Defendant Kobayashi--Harassment claim--
Emotional Pain & Suffering $ 100,000
Punitive Damages $ 20,000
Defendant Kobayashi--Retaliation claim--
Emotional Pain & Suffering $ 10,000
Punitive Damages $ 10,000
Defendant Knight--Retaliation claim--
Emotional Pain & Suffering $ 5,000
Punitive Damages $ 5,000
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