Farmer V. Ara Services Inc‪.‬

Appellant Local 1064 United Catering Restaurant, Bar and Hotel Workers Union appeals from a judgment of the district court in which the union was found guilty of violating Sections 8(b) and 9(a) of the Labor-Management Relations Act of 1947, 29 U.S.C. §§ 158(b) and 159(a) ("LMRA") and Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e, et seq. ("Title VII"). The Union alleges that the district court's findings of fact are clearly erroneous and that its conclusions of law are inconsistent with decisions of this circuit. For the reasons discussed below, we affirm the district court's factual findings on the liability issue. We also affirm the award of back pay and the award of damages for emotional and mental distress, but reverse the court's award of punitive damages.