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Hatley v. Hilton Hotels Corp.

The trial court erred in granting judgment as a matter of law on sexual harassment claims; the district court could not substitute its own determination of the witnesses' credibility for that of the jury.

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Plaintiffs-appellants appeal the district court’s rendering of judgment as a matter of law in favor of the defendants, on plaintiffs’ claims of sexual discrimination under Title VII of the Civil Rights Act of 1964, 42 U.S.C. �� 2000(e) et seq. and 42 U.S.C. � 1981a, and intentional infliction of emotional distress under Mississippi state law. The district court’s decision was rendered after a jury had found in favor of plaintiffs on both types of claims and awarded $150,000.00 in damages to each. In addition, the plaintiffs argue that the district court erred by refusing to instruct the jury on punitive damages. We reverse the district court’s judgment with respect to the sexual harassment claims, affirm with respect to the claims for intentional infliction of emotional distress and remand for a new trial on damages.

Plaintiffs, Lori Hatley (“Hatley”) and Habbakuk Cooper (“Cooper”), worked as cocktail waitresses at Bally’s Olympia, L.P. (“Bally’s”) in 1997 and 1998. At the district court, both of them alleged that they were subjected to sexual harassment from supervisors, and that even though they reported the harassment, Bally’s conducted only a sham investigation that ultimately led the two women to resign. 

Judgment as a matter of law should be rendered when “a party has been fully heard on an issue and there is no legally sufficient evidentiary basis for a reasonable jury to find for that party on that issue.” Fed. R. Civ. P. 50(a). “In entertaining a motion for judgment as a matter of law, the court should review all of the evidence in the record… [H]owever, the court must draw all reasonable inferences in favor of the nonmoving party, and it may not make credibility determinations or weigh the evidence.. . . 

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