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Anderson v. American Airlines

Citation: 352 F. App'x 182Docket: No. 08-16859

Court: Court of Appeals for the Ninth Circuit; November 5, 2009; Federal Appellate Court

Narrative Opinion Summary

In a case involving employment discrimination under the California Fair Employment and Housing Act, the plaintiff, an employee of American Airlines, alleged termination based on a perceived mental disability. The jury awarded the plaintiff $1 million for emotional distress and $238,333 for economic damages. American Airlines sought judgment as a matter of law and a new trial, both of which were denied by the district court. Upon appeal, the appellate court conducted a de novo review of the judgment motion and upheld the jury's verdict, finding it supported by substantial evidence viewed in the light most favorable to the plaintiff. The denial for a new trial was also affirmed, as there was no clear abuse of discretion. The appellate court found the damages not to be grossly excessive and dismissed claims of jury passion. Furthermore, the court upheld the jury instructions and evidentiary rulings, confirming they were proper and in accordance with legal standards. The appellate court ultimately affirmed the district court's decisions, with the disposition being unpublished and not precedential, except as allowed by Ninth Circuit Rule 36-3.

Legal Issues Addressed

Assessment of Damages and Jury Passion

Application: The appellate court dismissed claims of jury passion influencing excessive damages, finding the awarded damages were not grossly excessive.

Reasoning: American's claims of jury passion leading to excessive damages were dismissed, as the damages awarded were not deemed 'grossly excessive' or shocking.

Employment Discrimination under the California Fair Employment and Housing Act

Application: The plaintiff claimed her termination was motivated by perceived mental disability, and the jury found in her favor, awarding significant damages.

Reasoning: Greta Anderson sued American Airlines, Inc. for employment discrimination under the California Fair Employment and Housing Act, claiming her perceived mental disability was a motivating factor in her termination.

Evidentiary Rulings Under the Federal Rules of Evidence

Application: Evidentiary rulings were upheld as being within the district court's discretion, consistent with the Federal Rules of Evidence.

Reasoning: Additionally, the evidentiary rulings were also deemed within the district court's discretion under the Federal Rules of Evidence.

Jury Instructions and Abuse of Discretion

Application: The appellate court confirmed that the jury instructions were appropriate and accurately stated the law, finding no abuse of discretion.

Reasoning: The court reviewed jury instructions for abuse of discretion, confirming that the instructions adequately covered the issues and accurately stated the law.

Standard of Review for Judgment as a Matter of Law

Application: The appellate court conducted a de novo review of the district court's denial of American's motion for judgment as a matter of law, affirming the jury's verdict as supported by substantial evidence.

Reasoning: The appellate court reviewed the district court's decisions de novo regarding the judgment motion, affirming that the jury's verdict was supported by substantial evidence and met the legal standards.

Standard of Review for Motion for a New Trial

Application: The court emphasized the need for a clear abuse of discretion to reverse a denial for a new trial, which was not found in this case.

Reasoning: Regarding the motion for a new trial, the court noted that it would only reverse for a clear abuse of discretion, which was not present since substantial evidence supported the jury's verdict.