Equal Employment Opportunity Commissionv.Exel, Inc.
Contrice Travis sought a promotion at Exel, but her supervisor selected a male employee without considering other candidates. A jury found sex discrimination and awarded back pay, compensatory damages, and punitive damages. The district court denied Exel’s renewed motion for judgment as a matter of law on liability but set aside the punitive-damages award. The Equal Employment Opportunity Commission and Travis appealed, and Exel cross-appealed. The Eleventh Circuit affirmed. The majority held that sufficient evidence supported the jury’s finding that sex was a motivating factor in the promotion decision, while the evidence did not support punitive damages under the governing standard. The court also rejected the challenges to the trial court’s rulings and left the judgment intact. A dissent would have entered judgment for Exel because, in its view, the evidence did not show that the supervisor’s alleged bias actually motivated the promotion decision.
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