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Case Name Bryant v. Aiken Regional Med EE-SC-0048
Docket / Court 1:00CV01224 ( D.S.C. )
State/Territory South Carolina
Case Type(s) Equal Employment
Case Summary
In 2000, an African-American former hospital employee brought a suit against Aiken Regional Medical Centers in the U.S. District Court for the District of South Carolina. The case was assigned to District Judge Cameron M. Currie. Although the Plaintiff initially seemed to file the case as a class ... read more >
In 2000, an African-American former hospital employee brought a suit against Aiken Regional Medical Centers in the U.S. District Court for the District of South Carolina. The case was assigned to District Judge Cameron M. Currie. Although the Plaintiff initially seemed to file the case as a class action lawsuit, there is no reference to this on the docket. We do not have access to many of the documents, and so we do not have more information on how this issue was resolved.

Plaintiff alleged that the hospital engaged in racially discriminatory hiring and promotional practices, and retaliation against employees who complained about the discrimination, in violation of Title VII,  42 U.S.C. § 2000, and 42 U.S.C. § 1981. Plaintiff specifically alleged that ARMC had denied her a promotion on several occasions both because of her race and in retaliation for her complaints about discrimination in ARMC's hiring policies.

The case was tried before a jury on March 18, 19, and 20, 2002. The jury returned a verdict on March 20, 2002, in favor of Plaintiff on two of her three claims. The jury found that ARMC had refused to promote Plaintiff to a surgical technician position in retaliation for her complaints about racial discrimination. The jury also found that she had been denied a promotion to a registered nurse position because she was African–American. The jury found that racial discrimination was not a factor, however, in ARMC's failure to offer Plaintiff a surgical technician position. Bryant was awarded $40,000 in compensatory damages for lost wages and benefits, $50,000 for emotional distress, and $210,000 in punitive damages. The District Court treated the jury's verdict on back pay as an advisory verdict, and after independent consideration, the Court adopted the jury's verdict as the equitable award of back pay.

Prior to entering the judgement, the District Court requested that the parties brief the appropriateness of the jury's award of punitive damages. The District Court conducted a thorough review of the punitive damages award and concluded that the award was reasonable, appropriate, and fully supported by the evidence. In addition, the District Court awarded Plaintiff pre-judgment interest on the back-pay award, but denied Plaintiff's request to enhance the back-pay award to compensate her for the negative income-tax consequences of the verdict.

The District Court denied Defendant's post-trial motions for judgment as matter of law (JMOL) and a new trial on September 9, 2002. Defendant then appealed this case to the Fourth Circuit of the United States Court of Appeals, on September 30, 2002. Plaintiff cross-appealed with respect to the tax issue on October 9, 2002.

The appeal and cross-appeal was heard before Judges Harvie Wilkinson III, Paul V. Niemeyer, Robert B. King of the Fourth Circuit on May 8, 2003. On June 27, 2003, the Court issued its unanimous opinion. Judge Wilkinson, writing for the Court affirmed in part, and reversed in part. 333 F.3d 536 (4th Cir. 2003).

In its appeal, ARMC argued that the District Court erred in failing to grant judgment as a matter of law or a new trial, on both Plaintiff’s retaliation claim and her claim that they failed to promote her to nurse because of her race. The Court found that there was sufficient evidence to support the jury's verdict on these issues, and the district court did not abuse its discretion in refusing to grant a new trial on these scores.

ARMC also challenged the jury's award of $50,000 in compensatory damages for emotional distress. They argued that there was insufficient evidence to support such an award, and that the award was excessive. However, the Court held that the evidence presented at trial supported an award of damages for emotional distress, and that the amount was not excessive.

Lastly, ARMC challenged the award of punitive damages. The Court of Appeals found that that the trial judge erred by approving the jury's punitive damages award. The Court found that ARMC’s widespread anti-discrimination efforts (having a Equal Employment Opportunity Policy, grievance policy, and a diversity training program) precluded the award of punitive damages in this case. Citing the Supreme Court’s decision in Kolstad v. Am. Dental Assoc., 527 U.S. 526 (1999), the Court of Appeals reiterated that giving protection from punitive damages to “employers who make good-faith efforts to prevent discrimination in the workplace accomplishes Title VII's objective of motivat[ing] employers to detect and deter Title VII violations."

Regarding Plaintiff’s cross-appeal, the Court of Appeals held that the District Court did not abuse its discretion in denying her motion to enhance her backpay to compensate her for the negative income-tax consequences of the lump-sum nature of the verdict’s award.

The Plaintiff appealed to the Supreme Court of the United States regarding the tax issue and the Court of Appeal’s reversal of the punitive damages award. On January 12, 2004, the Supreme Court declined to hear the case. 540 U.S. 1106.

The case is closed.

Michael Beech - 02/26/2019


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Issues and Causes of Action
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Issues
Defendant-type
Hospital/Health Department
Discrimination-area
Promotion
Discrimination-basis
Race discrimination
EEOC-centric
Direct Suit on Merits
General
Disparate Treatment
Retaliation
Plaintiff Type
Private Plaintiff
Race
Black
Causes of Action 42 U.S.C. § 1981
Title VII (including PDA), 42 U.S.C. § 2000e
Defendant(s) Aiken Regional Medical Centers, Inc.
Plaintiff Description A former hospital employee who was denied a promotion on several occasions both because of her race and in retaliation for her complaints about discrimination in the hospital's hiring policies.
Class action status sought Yes
Class action status granted No
Filed Pro Se No
Prevailing Party Plaintiff
Public Int. Lawyer No
Nature of Relief Damages
Source of Relief Litigation
Form of Settlement Court Approved Settlement or Consent Decree
Filing Year 2000
Case Closing Year 2004
Case Ongoing No
Docket(s)
1:00-cv-01224-CMC (D.S.C.)
EE-SC-0048-9000.pdf | Detail
Date: 02/11/2004
Source: PACER [Public Access to Court Electronic Records]
General Documents
Opinion Revising Punitive Damage Payments (333 F.3d 536)
EE-SC-0048-0001.pdf | WESTLAW| LEXIS | Detail
Date: 06/27/2003
Source: Westlaw
show all people docs
Judges Currie, Cameron McGowan (D.S.C.) show/hide docs
EE-SC-0048-9000
King, Robert Bruce (Fourth Circuit) show/hide docs
EE-SC-0048-0001
Niemeyer, Paul Victor (D. Md., Fourth Circuit) show/hide docs
EE-SC-0048-0001
Wilkinson, J. Harvie III Court not on record show/hide docs
EE-SC-0048-0001
Plaintiff's Lawyers Rothstein, David E (South Carolina) show/hide docs
EE-SC-0048-9000
Defendant's Lawyers Belcher, Reginald W. (South Carolina) show/hide docs
EE-SC-0048-9000
Morgan, Richard J. (South Carolina) show/hide docs
EE-SC-0048-9000

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