In Williams v. ConAgra Poultry Co., 378 F.3d 790 (8th Cir. 2004), the Court of Appeals for the Eighth Circuit overturned a $6 million punitive damage award but sustained a compensatory damage award, all for racial discrimination.
The Court wrote:
- At the end of Mr. Williams's case and again at the close of evidence, ConAgra moved for judgment as a matter of law, which the district court denied. The jury then found for Mr. Williams on both claims, awarding him $927,788.90 in compensatory damages and $6,063,750 in punitive damages on the termination claim, and awarding him $1,001,397.40 in compensatory damages and $6,063,750 in punitive damages on the hostile work environment claim. ConAgra moved to set the verdicts aside and to remit the damages. The district court refused to set the verdicts aside, but it did remit the compensatory damages for the termination claim to $173,156 and the punitive damages on the same claim to $500,000. On the harassment claim, the court remitted the compensatory damages to $600,000 but let the exemplary damages award stand. Although it is not clear from the record, we assume that these awards were made under ยง 1981, which does not include the caps on damages contained in Title VII and the Arkansas Act.
The Court found the punitive damages to be unconstitutional for violation of the employer's rights of due process.