Quigley v. Winter, 598 F.3d 938 (2010)

Citation: Quigley v. Winter, 598 F.3d 938 (2010)
Parent Document: Quigley v. Winter, 598 F.3d 938 (2010)
Jurisdiction: United States (federal)
Effective Date: 2010-03-16
Original Source: https://www.courtlistener.com/opinion/231/quigley-v-winter/ ↗

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We first address Winter’s contention that the district court erred in allowing the jury to consider punitive damages. “The [FHA] provides for the recovery of punitive damages by victims of discriminatory housing practices.” Badami v. Flood, 214 F.3d 994, 997 (8th Cir.2000) (citing 42 U.S.C. § 3613(c)(1) (1994)). We apply the same standard for punitive damages in [FHA] cases as we do in employment discrimination and 42 U.S.C. § 1983 civil rights cases. Id. at 997 (referencing Kolstad v. Am. Dental Ass’n, 527 U.S. 526, 119 S.Ct. 2118, 144 L.Ed.2d 494 (1999)). “Punitive damages are appropriate in a federal civil rights action ‘when *953the defendant’s conduct is shown to be motivated by evil motive or intent, or when it involves reckless or callous indifference to the federally protected rights of others.’ ” Id. at 997 (quoting Smith v. Wade, 461 U.S. 30, 56, 103 S.Ct. 1625, 75 L.Ed.2d 632 (1983)). In Kolstad, a gender discrimination case, the Supreme Court held “[t]he terms ‘malice’ and ‘reckless [indifference]’ ultimately focus on the actor’s state of mind.” Kolstad, 527 U.S. at 535, 119 S.Ct. 2118 (citations omitted). They “pertain to the [defendant’s] knowledge that [he] may be acting in violation of federal law, not [his] awareness that [he] is engaging in discrimination.” Badami, 214 F.3d at 997 (quoting Kolstad, 527 U.S. at 535, 119 S.Ct. 2118). Thus, “it is sufficient that a defendant ‘discriminate in the face of a perceived risk that [his] actions will violate federal law to be liable in punitive damages.’ ” Id. (quoting Kolstad, 527 U.S. at 536, 119 S.Ct. 2118).

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