During a seven-day trial in 2022, a jury sided with Harris, awarding her $366 million, which included punitive damages, past pain and suffering, and future mental anguish. However, FedEx appealed, claiming that the evidence presented did not support such a large verdict and that Harris’ claims were time-barred by the contract’s six-month limitation.
Impact of the Fifth Circuit Ruling
The Fifth Circuit agreed with FedEx, ruling that the six-month limitation in Harris’ employment contract knocked out her Section 1981 claims. The panel noted this was crucial, as Title VII of the Civil Rights Act has a cap on damages, while Section 1981 does not. As a result, Harris’ compensatory damages were reduced to the statutory cap of $300,000 under Title VII.
In her petition to the Supreme Court, Harris also sought clarification on a circuit split regarding the “maximum recovery rule.” She argued that the Fifth Circuit improperly applied the rule, which limits compensatory damages, by focusing on proportionality to other cases rather than the quality of evidence, a method used by several other circuits.
Supreme Court Declines to Intervene
The Supreme Court, in a brief order list, denied Harris’ petition for certiorari, effectively upholding the Fifth Circuit’s ruling. The decision means that the $249,000 judgment, drastically reduced from the original $366 million, will stand.
