(CN) – The 8th Circuit increased a $20,500 punitive damages award to $54,750 for a low-income housing tenant who claimed she was sexually harassed by her landlord. The St. Louis court called the landlord’s conduct “unquestionably intentional and more than churlish.”
Jaymie Quigley’s former landlord, Dale Winter, allegedly entered her bedroom while she was gone, drunk dialed her at 2 a.m. or 3 a.m., stood “very close to Quigley and rubbed his genital area” and dropped in for unannounced inspections at night.
Quigley said Winter’s behavior made her uncomfortable, so she changed the locks without giving him a key.
When Quigley asked if she would be getting her deposit back, Winter “fluttered his hand against Quigley’s stomach and said, ‘My eagle eyes have not seen everything yet,'” the ruling states.
Quigley moved out before her lease was up, and Winter kept her deposit.
She filed suit in 2006, accusing Winter of sexual harassment, sex discrimination, coercion, intimidation, threats and interference with her housing rights.
The jury awarded her about $14,000 in compensatory damages and $250,000 in punitive damages, which the district court slashed to about $20,500.
Quigley and Winter both appealed; Quigley argued that the punitive damage award was too low, and Winter said no punitive damages were warranted.
Dismissing Winter’s cross-appeal, the 8th Circuit said there was enough evidence to support the jury’s verdict.
The three-judge panel found Winter’s conduct sufficiently reprehensible for punitive damages, but rejected both the jury’s award of 18 times the actual damages and the district court’s award of only 1.5 times compensatory damages.
The court settled on $54,750, an amount four times greater than Quigley’s compensatory damages award.
“This amount comports with due process, while achieving the statutory and regulatory goals of retribution and deterrence,” Judge William Jay Riley wrote.
The court also awarded her more than $78,000 in attorney fees and costs – higher than the $20,000 awarded by the district court, but lower than the $117,000 she requested.