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Zimmerman v. Direct Federal Credit Union

Supervisor's unlawful retaliation for female executive's discrimination complaint supported finding of tortious interference with executive's relationship with employer.

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APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS [Hon. Robert B. Collings, U.S. Magistrate Judge]

This appeal is the aftermath of a jury verdict that awarded plaintiff-appellee Celia Zimmerman $200,000 in compensatory damages and $400,000 in punitive damages on her claim for retaliation and an additional $130,000 in compensatory damages on her claim for tortious interference with advantageous relations. *fn2 Resolving the appeal requires us to realign the standard of review applicable to appeals from punitive damage awards in light of recent Supreme Court precedent. Before reaching this issue, however, we first must ponder two antecedent questions: (1) Does the evidence suffice to sustain the jury’s finding of tortious interference with advantageous relations? (2) Were the trial court’s jury instructions on compensatory damages adequate despite the court’s failure to address a plausible concern raised by the appellants? We answer these two questions in the affirmative, uphold the punitive damage award, and affirm the judgment below.

I. BACKGROUND

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