Khatabi v. Car Auto Holdings LLC
A jury awarded a car dealership employee $81,028 compensatory and $750,000 punitive damages on unallocated sex-discrimination claims brought under both Title VII and the Florida Civil Rights Act. The district court reduced the award to $181,028 by applying Title VII's $50,000 small-employer cap and awarding only under the FCRA. The Eleventh Circuit reversed, holding the plaintiff could recover the combined maximum of both statutes ($481,028 \u2014 $81,028 compensatory uncapped under the FCRA plus $400,000 punitive, being $100,000 under Fla. Stat. \u00a7 760.11(5) plus $300,000 under Title VII), and that the Title VII employee-headcount cap was a waived affirmative defense.
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