Rodriguez-Hernandez v. Miranda-Velez

Facts

P worked as an office manager for D. P started in the Traffic and Claims division of the Puerto Rico office. She was twice promoted and was put in charge of overseeing the daily operations of her office in February of 1990. P received regular praise for her work, and before the suspension and dismissal that led to this lawsuit, she had never been the subject of disciplinary action. D sells electrical and industrial equipment. D's most important market was Puerto Rico, and its most important customer was the Puerto Rico Electric Power Authority (PREPA). About 80% of D's business in Puerto Rico was with PREPA. Omar Chavez was the President and sole shareholder of D. Chavez employed young, attractive women, known to customers as 'Occidental Gals,' and instructed them to be especially cordial to PREPA employees. Edwin Miranda-Velez was the Chief of PREPA's Materials Management Division and the overseer of PREPA's public contracts for the type of goods sold by D. Chavez introduced P to Miranda, and told her that Miranda was very important for business and that she and the other employees should be nice to him and 'keep him satisfied.' P was instructed to visit Miranda every time she went to the PREPA offices. D made political contributions to the Popular Democratic Party, of which Miranda was a very active member, and solicited donations on its behalf. Chavez financed social activities for PREPA employees and gave Christmas presents to PREPA officials. Chavez threw a party for PREPA officials at a local hotel. The members of D, all female, were instructed to attend the event unaccompanied, so they would be available to dance with the PREPA executives. The night's entertainment at that party included a dancing show performed by scantily clad women. Chavez was able to learn from Miranda in advance what bids would be coming up and how much D's competitors were bidding. Miranda helped to steer business to Occidental through requests for proposals that were handled outside the ordinary bidding process. Miranda began to make sexual approaches and suggestive comments to P. He invited her out to dinner. He asked her to visit his office after hours and on Friday evenings. He anonymously sent her flowers for her birthday and included a sexually explicit card. P complained to Chavez about this behavior; Chavez responded by stressing that Miranda was an important client, but assured her that he would deal with the problem. Miranda called P and told her he would come pick her up to take her to a motel. Chavez responded by defending Miranda, and saying that P should respond to Miranda 'as a woman.' P threatened to take her complaints to the Director of PREPA. Chavez suspended P from work for thirty days. It was because of unauthorized use of company property, contracting for services in the company name without authorization, and absenteeism. O was fired a month later for an unexplained imbalance of $157.00 in petty cash funds and negligence in executing daily functions such as picking up company mail, as well as the previous problems noted the month before. P sued Ds under 42 U.S.C. §1983 for violations of her rights under the Fifth, Ninth, and Fourteenth Amendments, and sued both Miranda and PREPA under Puerto Rico tort law and the Puerto Rico Constitution. P received a right-to-sue letter from the EEOC and named Chavez and D as defendants and asserted claims under Title VII. During trial, Ds attempted to paint the plaintiff as sexually insatiable, as engaging in multiple affairs with married men, as a lesbian, and as suffering from a sexually transmitted disease. The court ruled that only evidence relating to Miranda and P’s work was admissible, barring the remaining evidence under Rule 412. The jury held D and Chavez liable but found Miranda and PREPA not liable. P received an award of $200,000 in compensatory and punitive damages against D and Chavez. Ds appealed. P cross-appeals, for more attorney fees.

Issues

Rule of Law

Holding and Decision

Legal Analysis

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