Title VII Violation – Damages

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7^th Circuit Court of Appeals

Case Name: Lydia E. Vega v. Chicago Park District

Case No.: 19-1926; 19-1939

Officials: WOOD, Chief Judge, and EASTERBROOK and BARRETT, Circuit Judges.

Focus: Title VII Violation – Damages

Lydia Vega sued her former employer, the Chicago Park District, alleging that the Park District discriminated against her due to her national origin in violation of Title VII and 42 U.S.C. § 1983. After a seven- day jury trial, the jury returned a verdict in Vega’s favor on both claims and awarded her $750,000 in compensatory damages. The Park District moved for judgment as a matter of law on both claims; the district court granted the motion with respect to the § 1983 claim but denied it with respect to the Title VII claim. With the § 1983 claim gone, the district court remitted Vega’s award to $300,000, which is the statutory maximum under Title VII. It then conducted a bench trial on equitable remedies and granted Vega back pay, benefits, and a tax-component award.

On appeal, the Park District challenges the district court’s denial of its motion for judgment as a matter of law on Vega’s Title VII claim, several evidentiary rulings, the statutory maximum damages award, and the calculation of equitable remedies. Vega cross-appeals the district court’s entry of judgment as a matter of law on her § 1983 claim. We affirm all of the district court’s rulings except its grant of the tax-component award, which we vacate and remand for the district court to explain its calculation.

Affirmed

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Derek A Hawkins is trademark corporate counsel for Harley-Davidson. Hawkins oversees the prosecution and maintenance of the Harley-Davidson’s international trademark portfolio in emerging markets.