Gyulakian v. Lexus of Watertown, Inc., et al. (Lawyers Weekly No. 10-134-16)
NOTICE: All slip opinions and orders are subject to formal revision and are superseded by the advance sheets and bound volumes of the Official Reports. If you find a typographical error or other formal error, please notify the Reporter of Decisions, Supreme Judicial Court, John Adams Courthouse, 1 Pemberton Square, Suite 2500, Boston, MA, 02108-1750; (617) 557-1030; SJCReporter@sjc.state.ma.us SJC-11959 EMMA GYULAKIAN vs. LEXUS OF WATERTOWN, INC., & another.[1] Middlesex. March 10, 2016. – August 24, 2016. Present: Gants, C.J., Spina, Cordy, Botsford, Duffly, & Lenk, JJ.[2] Employment, Sexual harassment. Anti-Discrimination Law, Sex, Attorney’s fees. Practice, Civil, Judgment notwithstanding verdict. Damages, Punitive. Civil action commenced in the Superior Court Department on January 10, 2013. The case was tried before Kimberly S. Budd , J., and postverdict motions for relief were considered by her. The Supreme Judicial Court granted an application for direct appellate review. Robert S. Mantell (Lori A. Jodoin with him) for the plaintiff. Christopher J. Sullivan (Tory A. Weigand with him) for the defendants. The following submitted briefs for amici curiae: Rebecca Pontikes, Katherine Skubecz, Michaela C. May, & Chetan Tiwari for Massachusetts Employment Lawyers Association & others. Afton M. Templin for Women’s Bar Association of Massachusetts. Ben Robbins & Martin J. Newhouse for New England Legal Foundation & another. Elizabeth S. Dillon for Massachusetts Defense Lawyers Association. CORDY, J. In December, 2014, a jury rendered a verdict in favor of the plaintiff, Emma Gyulakian, finding that she had been subjected to a sexually hostile or offensive work environment, in violation of G. L. c. 151B (c. 151B), § 4 (§ 4).[3] The jury, having heard evidence tending to establish that Gyulakian suffered relentless sexual harassment by her direct supervisor, Emmanuel Ferreira, found that the defendants, Lexus of Watertown, Inc., and Post Motors, Inc. (collectively, Lexus), were liable for $ 40,000 in compensatory damages for emotional distress, and, concluding that Lexus acted intentionally or with reckless disregard for Gyulakian’s rights under the discrimination laws, also awarded Gyulakian $ 500,000 in punitive damages. Lexus filed a motion for judgment notwithstanding the verdict (judgment n.o.v.), or, in the alternative, for a new trial or a remittitur. A judge of the Superior Court allowed the defendant’s motion for judgment n.o.v. in part, denying the motion with respect to the jury’s imposition of compensatory damages but allowing it as to the award of punitive damages. Gyulakian appealed on the issue of punitive damages, and Lexus cross-appealed the award of compensatory damages. We allowed Gyulakian’s application for direct appellate review and affirm the award of compensatory damages. We also reverse the trial judge’s ruling as to the punitive damages award, because, […]