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Efrain A. Ramirez v. New York City Off-Track Betting Corp.

Citations: 112 F.3d 38; 1997 U.S. App. LEXIS 4021; 73 Fair Empl. Prac. Cas. (BNA) 573; 1997 WL 191358Docket: 963

Court: Court of Appeals for the Second Circuit; February 23, 1997; Federal Appellate Court

Narrative Opinion Summary

In this case, a plaintiff, employed by New York City Off-Track Betting Corporation (OTB), alleged ethnic discrimination, retaliation, and denial of due process following his termination. The plaintiff's stepfather, a former OTB executive, was terminated after expressing concerns about discriminatory practices, and the plaintiff was later placed on inactive status, losing medical benefits and ultimately being discharged. The plaintiff claimed his termination was retaliatory and violated due process as his appeals were ignored. The jury awarded $2.58 million for the retaliation and due process claims, but not for ethnic discrimination. Upon OTB's motion for a new trial, citing improper attorney summation and an excessive verdict, the court reduced the pain and suffering award via remittitur, upheld by the plaintiff, resulting in $1,934,375 in damages. On appeal, OTB argued for a new trial or increased remittitur, emphasizing the lack of discounting future earnings. The court affirmed the remittitur but remanded the case to apply a 2% discount rate to future earnings and medical costs, aligning with circuit requirements. The court rejected claims of excessive pain and suffering damages, supporting the jury's findings of the plaintiff's permanent unemployability.

Legal Issues Addressed

Discount Rate for Future Earnings

Application: The circuit requires that future earnings be discounted to reflect the time value of money, and the case was remanded to apply a 2% discount rate.

Reasoning: The case is remanded for recalculation using an appropriate discount rate of 2% for lost income and medical costs, without the need for new evidence.

Due Process in Employment Termination

Application: The jury found that the plaintiff's due process rights were violated during his termination, as his requests to appeal the termination were ignored by the employer.

Reasoning: Despite multiple requests to appeal his termination, OTB did not respond.

Ethnic Discrimination under Title VII

Application: The plaintiff's claim of ethnic discrimination under Title VII was not upheld by the jury, indicating insufficient evidence to support this allegation.

Reasoning: The jury found in favor of Ramirez on the retaliation and due process claims, awarding him $2.58 million, but ruled against him on the discrimination claim.

Jury Award and Remittitur

Application: The court ordered a remittitur due to the excessive nature of the pain and suffering award, reducing the total damages awarded to the plaintiff.

Reasoning: Consequently, a remittitur of $645,625 was ordered, which the plaintiff accepted, resulting in total damages of $1,934,375.

Prejudicial Error and Remittitur Justification

Application: A new trial was not warranted as the trial was free from prejudicial error, making the remittitur appropriate.

Reasoning: The trial was deemed free of error, justifying the remittitur rather than a new trial.

Retaliation Claims

Application: The jury concluded that the plaintiff was retaliated against due to his familial association with a former employee who raised concerns about discriminatory practices.

Reasoning: The jury found in favor of Ramirez on the retaliation and due process claims, awarding him $2.58 million, but ruled against him on the discrimination claim.