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Oliveras-Zapata v. Univision Puerto Rico, Inc.

Citations: 939 F. Supp. 2d 82; 2012 WL 7961875; 2012 U.S. Dist. LEXIS 187682Docket: CIV. No. 09-1987 (BJM)

Court: District Court, D. Puerto Rico; April 30, 2012; Federal District Court

Narrative Opinion Summary

In this case, a jury found Univision Puerto Rico, Inc. liable for retaliation against the plaintiff under the Age Discrimination in Employment Act, Title VII, and Puerto Rico’s Law No. 115, awarding substantial damages. Univision sought to overturn the verdict through post-trial motions, including a Motion for Judgment as a Matter of Law under Rule 50 and a Motion for New Trial under Rule 59, both of which were denied by the court as the jury's findings were deemed reasonable based on the evidence presented. Univision challenged the damages as excessive, leading the court to conditionally grant a new trial on compensatory damages unless the plaintiff accepted a reduced award. Similarly, a new trial on backpay was granted unless the plaintiff agreed to a reduction. The court highlighted the sufficiency of evidence for the retaliation claim, focusing on the necessary causal connection between the plaintiff's discrimination complaints and subsequent adverse employment actions. The court's decision emphasized reliance on specific evidentiary support rather than comparisons with other cases, requiring the plaintiff to decide on accepting the revised damages by a specified date.

Legal Issues Addressed

Backpay Calculation Discrepancies

Application: The court granted a new trial on backpay unless Oliveras remits $44,407, as the awarded amount exceeded what Oliveras calculated.

Reasoning: The court agrees, granting a new trial on backpay unless Oliveras remits $44,407.

Establishing a Prima Facie Case for Retaliation

Application: The court acknowledged the necessity of a causal connection between adverse actions and protected activity in retaliation claims.

Reasoning: The court acknowledges that for a retaliation claim, a causal connection is necessary, especially when adverse actions occur after protected activity.

Motion for Judgment as a Matter of Law under Rule 50

Application: Univision's motion for judgment was denied as the court emphasized the need to view evidence favorably toward the jury's verdict.

Reasoning: The court evaluated Univision's claims, emphasizing that it must view the evidence favorably toward the jury's verdict without assessing witness credibility or evidence weight.

Motion for New Trial under Rule 59

Application: The court denied Univision's motion for a new trial, finding that the evidence did not outweigh the jury's verdict sufficiently to cause a miscarriage of justice.

Reasoning: Regarding the Rule 59 motion for a new trial, the court highlighted that while evidence could have supported a verdict for Univision, it did not outweigh the jury's verdict to the extent that a miscarriage of justice would occur.

Remittitur and Excessive Damages

Application: The court found the compensatory damages excessive and offered a remittitur, capping them at $500,000 based on evidentiary support.

Reasoning: The court finds the jury's award disproportionate, capping compensatory damages at $500,000 based on evidentiary support, thereby granting Univision a new trial on compensatory damages unless Oliveras remits $600,000.

Retaliation under the Age Discrimination in Employment Act and Title VII

Application: The court upheld the jury's verdict that Univision retaliated against Oliveras for his discrimination claims.

Reasoning: The court found sufficient evidence for the jury to reasonably conclude that Univision retaliated against Oliveras for his discrimination claims, including willfulness warranting punitive damages.