Background
Rose Griffin sued her employer, Copper Cellar Corporation, alleging a hostile work environment and retaliation under Title VII. A jury found in her favor on the hostile work environment claim but not on the retaliation claim. The jury awarded Griffin $179,000 in compensatory damages and $314.22 in back pay. The district court also approved $480,364.50 in attorney fees. Copper Cellar appealed, challenging the back pay award, the compensatory damages, and the attorney fees.
The court’s reasoning
The court affirmed the back pay award, noting that Sixth Circuit precedent does not require a finding of discriminatory discharge to award back pay for a hostile work environment. Regarding compensatory damages, the court found the evidence of severe emotional distress, including nightmares and a suicide attempt, sufficient to support the award. The court also affirmed the attorney fees, stating that the plaintiff’s recovery was far greater than the defendant’s settlement offer, justifying the full award.
The jury heard testimony … about the substantial negative physical and emotional effects [Griffin] suffered, and the district court did not abuse its discretion in rejecting the argument that the jury’s award was out of proportion to her suffering.
Griffin v. Copper Cellar Corp., 26a0205n.06 (6th Cir. 2026)
What it means going forward
The decision reinforces that employers may be liable for back pay and significant compensatory damages in hostile work environment cases even if the employee was not formally fired, provided the harassment caused the employee to leave.
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