Issue: Does Title VII of the Civil Rights Act eliminate any claims under Texas law for punitive damages for intentional infliction of emotional distress?
|Area of Law:||Constitutional Law, Employee Law, Litigation & Procedure|
|Keywords:||Punitive damages; Intentional infliction of emotional distress claim; Damage caps|
|Cited Statutes:||42 U.S.C. § 1981a; 42 U.S.C. § 2000e-7; Title VII of the Civil Rights Act|
Title VII itself unequivocally proclaims that nothing therein “shall be deemed to exempt or relieve any person from any liability, duty, penalty, or punishment provided by any present or future law of any State.” 42 U.S.C. § 2000e-7 (2000).
Under Texas law, there is no cap on punitive damages for intentional infliction of emotional distress. But by applying the damage caps in 42 U.S.C. § 1981a to all of the damages awarded, a court would be effectively treating a plaintiff’s claims and the damages awarded thereunder as arising only under Title VII. That result is directly contrary to the mandates of the Civil Rights Act that no provision of the Act be applied to exempt any defendant from liability provided by state law.