Court of Appeals Affirms Judgment for Plaintiff in Action for Hostile Work Environment and Retaliation Under DCHRA
On May 31, 2012, the District of Columbia Court of Appeals decided Campbell-Crane & Assocs., Inc. v. Stamenkovic, Nos. 09-CV-64 & 09-CV-461, slip op. (D.C. May 31, 2012) in which it affirmed a judgment awarding compensatory damages, attorneys’ fees, and costs to a plaintiff who alleged claims for hostile work environment and retaliation under the District of Columbia Human Rights Act (“DCHRA”), D.C. Code §§ 2-1402.01 et seq. The case arose from alleged sexual harassment and related misconduct by a female supervisor/owner of a company against the plaintiff, a male employee of the company. The employee subsequently filed suit against the supervisor/owner and the company. The case went to trial and a jury awarded the plaintiff $812,000 in compensatory damages, almost all of which was for emotional distress due to the alleged hostile work environment. The trial judge subsequently awarded approximately $456,000 in attorneys’ fees and costs. The defendants appealed. The Court of Appeals affirmed the judgment in its entirety. It agreed with the defendants that the jury was not properly instructed on the hostile work environment claim, but ruled that the error was harmless. It also ruled that the trial court did not err in deciding not to instruct the jury on nominal damages, allowing the plaintiff to call a rebuttal witness to impeach the supervisor/owner’s trial testimony, and excluding certain evidence which the defendants’ wanted to introduce to prove alternative causes for the plaintiff’s emotional distress. Finally, the Court of Appeals ruled that the award of compensatory damages was not extraordinarily disproportionate to the alleged emotional distress and that the trial court did not abuse its discretion in awarding attorneys’ fees and costs.