Antidiscrimination Statutes Cover Retaliation Claims Against Unions Which Cause Harm In The Workplace And Outside Of It
This case stems from an ugly incident of verbal abuse of a female police officer by her fellow male officers during a union-sponsored bus trip in the fall of 1998, as well as from the actions of the union and its members in response to the investigations of her complaints in the years that followed.
The female officer, Vanessa Dixon, eventually brought a civil suit in federal court against the national union and its local chapter, their presidents, and two of the police officers involved in the incident, asserting claims of discrimination and retaliation. The jury found for Dixon, awarding her a total of $1,205,000 in compensatory damages and $1,027,501 in punitive damages.
On appeal, the 1st Circuit affirmed, holding that: (1) both Title VII and the Massachusetts antidiscrimination statute cover retaliation claims against unions which cause harm in the workplace and outside of it; and (2) the evidence supported the punitive damages award under state law.
Dixon v. International Brotherhood
The 1st Circuit Court of Appeals’ jurisdiction includes Maine, Massachusetts, New Hampshire, Puerto Rico and Rhode Island.