Kolstad v. American Dental Association
527 U.S. 526 (1999)
Legal Analysis
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Nature Of The Case
This section contains the nature of the case and procedural background.
Facts
Jack O'Donnell announced that he would be retiring as the Director of Legislation and Legislative Policy and Director of the Council on Government Affairs and Federal Dental Services for D. P was employed with O'Donnell in the D. C. office, where she was serving as D's Director of Federal Agency Relations. When she learned of O'Donnell's retirement, she expressed an interest in filling his position. Tom Spangler, another employee in D's Washington office, was also interested in the same position. Spangler was serving as the Association's Legislative Counsel, a position that involved him in D's legislative lobbying efforts. Both petitioner and Spangler had worked directly with O'Donnell, and both had received 'distinguished' performance ratings by the acting head of the Washington office, Leonard Wheat. Wheat requested that Dr. William Allen, then serving as D's Executive Director in the Chicago office, make the ultimate promotion decision. After interviewing both P and Spangler, Wheat recommended that Allen select Spangler. P eventually sued D, claiming discrimination. P claimed the stated reasons for selecting Spangler were a pretext for gender discrimination, and that Spangler had been chosen for the position before the formal selection process began. There was testimony to the effect that Allen modified the description of O'Donnell's post to track aspects of the job description used to hire Spangler. P introduced testimony at trial that Wheat told sexually offensive jokes and that he had referred to certain prominent professional women in derogatory terms. Wheat allegedly refused to meet with P for several weeks regarding her interest in O'Donnell's position. P testified that she had historically experienced difficulty gaining access to meet with Wheat. The District Court denied P's request for a jury instruction on punitive damages. The jury concluded that D had discriminated on the basis of sex and awarded her backpay totaling $52,718. The court made clear that it had not been persuaded that D had selected Spangler over P on the basis of sex, and the court denied P's requests for reinstatement and for attorney's fees. P appealed. The court reversed the District Court's decision denying P's request for an instruction on punitive damages. The court rejected D's claim that punitive damages are available under Title VII only in ''extraordinarily egregious cases.'' The Court of Appeals agreed to rehear the case en banc, limited to the punitive damages question. The court determined that a defendant must be shown to have engaged in some 'egregious' misconduct before the jury is permitted to consider a request for punitive damages. P appealed.
Issues
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Rule Of Law
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Holding & Decision
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