Ogden v. Wax Works

Appeal from the United States District Court for the Northern District of Iowa Submitted: December 17, 1999 I. Wax Works, Inc. (Wax Works) appeals a post-trial order of the United States District Court for the Northern District of Iowa, 1 denying its motion for JAML, or, alternatively, new trial, following a jury verdict in favor of plaintiff/appellee Kerry D. Ogden (Ogden) on her claims of unlawful employment discrimination in violation of Title VII. 2 Following a five day trial, the jury found Ogden was subjected to hostile environment and quid pro quo sexual harassment, and retaliation, and further found Ogden was constructively discharged. The jury awarded Ogden $40,000.00 in compensatory damages, $792.00 in pre-termination back pay, $75,599.00 in post-termination back pay, and $500,000.00 in punitive damages ($300,000.00 on the hostile environment claim and $200,000.00 on the retaliation claim). The district court entered judgment accordingly, save for the punitive damages award, which was reduced to $260,000.00 pursuant to 42 U.S.C. § 1981a(b)(3)(D). The district court also awarded Ogden $69,768.00 in front pay.