Bennett v. CSX Transportation, Inc. (Fourth Circuit)
The plaintiff in this case was on duty as a trainee-conductor for CSX when her vehicle was subjected to racially offensive vandalism in the company parking lot. Although the police were unable to identify the culprit, the plaintiff brought a Title VII hostile-environment suit against the company, asserting that CSX was liable because the vandalism could potentially have been committed by one of its supervisory employees. The jury found for the plaintiff and awarded her $150,000 in compensatory damages; the court then added nearly $600,000 in front pay (one of the largest front-pay awards ever in a Title VII case), nearly $100,000 in back pay, and nearly $800,000 in attorneys’ fees. We convinced the Fourth Circuit to reverse the verdict in its entirety and direct entry of judgment in favor of CSX, making this one of the rare cases in which a federal appellate court was persuaded to overturn a jury verdict on sufficiency-of-the-evidence grounds.