Speedway Superamerica v. Dupont

Dupont, employed by Speedway convenience stores, sued Speedway alleging sexual harassment and hostile work environment. Dupont’s complaint stemmed from her interactions with a coworker, Coryell. For months, Dupont had complained to her superiors that Coryell acted inappropriately with her, both violently and sexually. For instance, Dupont complained that Coryell had inappropriately grabbed her, made sexual comments concerning female customers, and humiliated her. On appeal from a jury verdict, Speedway argued that it was entitled to summary judgment because the record did not establish that the misconduct was directed at Dupont because of her gender and the evidence did not establish that the conduct was so severe or pervasive that it established a hostile work environment. Speedway also argued that it was entitled to a directed verdict because it took prompt remedial action to address Dupont’s complaints. Finally, Speedway argued that the plaintiff should be barred from collecting $75,000 or more because she successfully filed to have the case remanded back to state court on the grounds that the amount in controversy was no more than $50,000 after Speedway obtained removal to federal court. The Court upheld the jury verdict. It found that Coryell’s conduct was motivated by a hostility toward women because of their gender and that the conduct was sufficiently severe and pervasive to alter the conditions of Dupont’s employment. Finally, the court found that the award of punitive damages was appropriate because Coryell’s conduct was clearly willful, Speedway had been at least negligent in failing to promptly and adequately respond to Dupont’s complaints, and Dupont requested remand to state court in good faith.