Carleen Black v. Pan American Laboratories, L.L.C.; Pamlab, L.L.C.

Summary

Carleen Black sued Pamlab under Title VII and the Texas Commission on Human Rights Act, alleging sex discrimination in sales quotas and termination, as well as retaliation. The Fifth Circuit affirmed the liability verdict and held that Title VII's compensatory and punitive damages cap applies per litigant, not per claim. It reversed and remanded the quota-claim back-pay award for recalculation based on the difference between Black's actual commissions and those she would have earned under the male comparator's quota.

Holdings

1. The evidence was sufficient for a reasonable jury to find that Black's sex was a motivating factor in Pamlab's decision to terminate her; the district court properly denied renewed JMOL.
2. Sufficient evidence supported the jury's finding that Pamlab discriminated against Black by assigning her a higher sales quota than a similarly situated male employee.
3. The jury's $150,000 back pay award on the quota claim was unsupported because the evidence supported only the disparate-treatment theory submitted to the jury, under which back pay had to be calculated using Livingston's quota rather than a zero-quota calculation.
4. The cap in 42 U.S.C. § 1981a(b) applies per complaining party in an action, not separately to each legal claim. The district court properly limited Black's total compensatory and punitive damages to $200,000.

Questions Presented

1. Whether sufficient evidence supported the jury's finding that sex was a motivating factor in Pamlab's termination of Black.
2. Whether sufficient evidence supported the jury's finding that Pamlab discriminated against Black by assigning her a higher sales quota than a similarly situated male employee.
3. Whether the quota-claim back pay award was supported by the theory submitted to and decided by the jury.
4. Whether sufficient evidence supported the jury's punitive-damages award.
5. Whether Title VII's compensatory and punitive damages cap applies per claim or per complaining party in a single action.

Disposition

reversed_and_remanded