On May 16, 2017, we reported that a jury in Davis v. Packer Engineering, Inc., No. 1:11-cv-07923, awarded plaintiffs Danya Davis and Bernessa Wilson each $3 million in punitive damages and $150,000 and $300,000, respectively, in compensatory damages. In that case, the plaintiffs had alleged, among other things, that their employers subjected them to a hostile work environment and retaliated against them for complaining about such environment by terminating their employment. At that time, we noted that the jury award far exceeded the statutory caps imposed by Title VII.

On August 2, 2017, U.S. District Judge Andrea Wood slashed the $6.45 million award to $100,000, with Davis and Wilson each receiving $50,000. Judge Wood explained that, pursuant to Title VII’s statutory cap, a plaintiff cannot recover more than $50,000 where the employer has more than “14 and fewer than 101 employees in each of 20 or more calendar weeks in the current or preceding calendar year.” Packer’s payroll records show its workforce fell within that range in the relevant years.