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

Citation: Quigley v. Winter, 598 F.3d 938 (2010) 1.
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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1.       Punitive Damages
                      a. Punitive Damages Jury Instruction
       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 (1999)). “Punitive damages are appropriate in a federal civil
rights action ‘when the 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 (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 (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).
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).

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