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
Last week, I posted the 
Last summer, my colleague C.J. Summers and I posted 
Last October, I 
By now, you’ve probably read reports of the $8 billion punitive verdict against Johnson & Johnson in an individual case alleging failure to warn that young men using its antipsychotic drug Risperdal could develop breasts. Robot-like, virtually every article about the verdict says that the verdict is likely to be reduced because it is disproportionate to the $680,000 award of compensatory damages.
Although the Supreme Court identified three guideposts for evaluating whether a punitive award is unconstitutionally excessive 23 years ago in 
On June 24, the Supreme Court held in 
In an earlier 
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