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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

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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.