Vance v. Union Planters Corp‪.‬

Appeal from the United States District Court for the Northern District of Mississippi Yvonne Vance sued Union Planters Bank, N.A. (""Union Planters""), under title VII, alleging discriminatory failure to promote on the basis of sex. A jury awarded $30,000 for lost wages and benefits, $20,000 for emotional distress, and $390,000 in punitive damages. The district court later reduced the total amount awarded to $330,000 because of title VII's statutory limits on employer liability. Union Planters appealed, asserting that (1) no reasonable jury could have found sex discrimination, (2) the court erred in allowing the jury to hear evidence that Union Planters had previously been found to have violated the Equal Pay Act, and (3) the district court erroneously determined Union Planters's size for purposes of the statutory liability limits. We affirm with regard to the first two issues and vacate and remand on the third issue. I.