Skip to main content
DRAFT FOR ATTORNEY REVIEW — NOT FINAL

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)
Effective Date
2010-03-16

Other Sections in This Document (232)

Full Text

781 chars
Winter’s conduct was reprehensible. Quigley lived alone with small children at the time of Winter’s harassment, and she had few, if any, alternative housing options. Quigley’s financial vulnerability was evidenced by her need for Section 8 housing vouchers. Winter held a certain level of power over Quigley and her family. Winter repeatedly subjected Quigley to inappropriate conduct during Quigley’s tenancy, and Winter’s conduct was unquestionably intentional and more than churlish. Most significant, Winter’s conduct intruded upon Quigley’s sense of security in her own home. However, as we explain below, we do not believe the degree of reprehensibility of Winter’s conduct justifies the jury’s large punitive damages award. ii. Ratio Between Punitive Damages and Actual Harm