Elizabeth Graham v. Bristol Hospice Holdings, Inc.

Summary

The United States District Court for the District of Utah denied Bristol Hospice Holdings, Inc.’s Rule 50 motion for judgment as a matter of law on Elizabeth Graham’s Title VII retaliation claim and punitive damages. The court held that sufficient evidence supported a reasonable jury finding that Graham’s termination was caused by protected activity and that the employer acted with the requisite knowledge of Title VII requirements. The court also granted Graham’s motion concerning the Kolstad defense, finding insufficient evidence to support instructing the jury on that defense.

Holdings

1. Judgment as a matter of law was not warranted because the evidence, viewed in Graham's favor, would permit a reasonable jury to find that her protected activity was the but-for cause of her termination.
2. Judgment as a matter of law was not warranted on punitive damages because sufficient evidence would permit a reasonable jury to find that Bristol Hospice acted with malice or reckless indifference to Graham's federally protected rights.
3. The Kolstad good-faith defense was unavailable on the evidence and should not be submitted to the jury.

Questions Presented

1. Whether Bristol Hospice was entitled to judgment as a matter of law on Graham's Title VII retaliation claim.
2. Whether Bristol Hospice was entitled to judgment as a matter of law on punitive damages.
3. Whether the jury should be instructed on the Kolstad good-faith defense to punitive damages.

Disposition

other