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Hetzel v. Prince William County

Supreme Court of the United States · 1998 · Civil Procedure

Civil ProcedureSeventh AmendmentRemittiturSeventh Amendmentjury trialremittiturdamagesexcessive verdict

Facts

A jury found for Hetzel on claims against Prince William County under Title VII and 42 U.S.C. § 1983 and awarded $750,000 in damages. The District Court reduced the award to $500,000 because one supporting claim was legally insufficient. On appeal, the Fourth Circuit affirmed liability but held the damages award grossly excessive and remanded for recalculation of emotional-distress damages. On remand, the District Court awarded $50,000; when Hetzel rejected that amount and sought a new trial, the District Court granted a new trial on damages, but the Fourth Circuit issued mandamus ordering entry of judgment on the reduced award.

Issue

When an appellate court determines that a jury's damages award is excessive and orders a reduced amount, may it require the trial court to enter judgment for that lesser amount without giving the plaintiff the option of a new trial? Does such a mandate violate the Seventh Amendment?

Rule

Under the Seventh Amendment, when a court concludes that a jury's damages award is excessive and effectively imposes a remittitur, the plaintiff must be given the choice between accepting the reduced award and obtaining a new trial. A court may not enter absolute judgment for a lesser sum than the jury assessed based on the court's own estimate of proper damages.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

A jury in federal court in Chicago finds Lakeshore Transit Services liable to Dana Kim for workplace retaliation and awards $420,000 for emotional distress. The court of appeals affirms liability but concludes the distress award is unsupported by the trial evidence and directs the district court on remand to enter judgment for $80,000.

Dana rejects the $80,000 figure and asks for a new trial limited to damages. What is the best answer?

Explanation. When a court determines that a jury's damages award is excessive and substitutes a lower amount, that functions as a remittitur. Under the Seventh Amendment, the plaintiff must be allowed to choose between accepting the reduced amount and obtaining a new trial; a court may not enter absolute judgment for the lesser sum based on its own damages assessment. (Derived from Hetzel v. Prince William County (1998).)