Making important law on the question of vicarious liability for punitive damages, the Fourth Circuit recently reversed awards of punitive damages under Title VII and North Carolina law in Ward v. AutoZoners.
The case involved alleged peer-on-peer sexual harassment at an AutoZone store. Keith Ward, an AutoZone employee, reported to multiple supervisors that a coworker, Christina Atkinson, had targeted him repeatedly for lewd remarks and inappropriate physical contact. Ward alleged that the supervisors took ineffective action in response, causing him to suffer anxiety, stress, and chest pains that required medical attention. Continue Reading Fourth Circuit Reverses Findings Of Vicarious Punitive Liability Under Title VII And North Carolina Law