Supreme Court of the United States
Kolstad v. American Dental Association
June 22, 1999527 U.S. 526
Summary
Justice O'Connor's opinion, supported by different majorities for its principal parts, held that punitive damages under Title VII do not require independently egregious misconduct. Instead, the employer must discriminate with knowledge that it may be violating federal law. Agency principles constrain attribution of punitive liability, and an employer is not vicariously liable for managerial agents' discriminatory employment decisions contrary to its good-faith efforts to comply with Title VII. The Court vacated the Court of Appeals' judgment and remanded without deciding whether Kolstad's evidence satisfied these standards. Chief Justice Rehnquist, joined by Justice Thomas, would have required egregious misconduct but agreed that agency principles significantly limit punitive liability. Justice Stevens, joined by Justices Souter, Ginsburg, and Breyer, agreed that no independent egregiousness requirement applies but opposed reaching the agency issue and would have ordered a trial on punitive damages.
Holding
- Whether independently egregious misconduct is required for punitive damages under Title VII.. Section 1981a(b)(1) does not require egregious or outrageous discrimination independent of the employer's state of mind, although egregious conduct may establish the required mental state.
- What mental state supports punitive damages under § 1981a(b)(1).. An employer must at least discriminate in the face of a perceived risk that its conduct will violate federal law; intentional discrimination alone does not necessarily establish punitive liability.
- When discriminatory decisions by managerial agents support an employer's vicarious liability for punitive damages.. Agency principles limit vicarious punitive liability, and an employer may not be held vicariously liable for managerial agents' discriminatory employment decisions that are contrary to the employer's good-faith efforts to comply with Title VII.
Docket 98-208
Cited authorities
- Rule 14.1(a)
- Rule 15.2
- CA11
- CA10
- 105 Stat. 1071
- 78 Stat. 253
- 104 Stat. 328
- 42 U.S.C. § 12101
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