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 — $81,028 compensatory uncapped under the FCRA plus $400,000 punitive, being $100,000 under Fla. Stat. § 760.11(5) plus $300,000 under Title VII), and that the Title VII employee-headcount cap was a waived affirmative defense.
Key facts
- Khatabi, a car dealership employee, brought sex-discrimination claims against Car Auto Holdings LLC under both Title VII of the Civil Rights Act and the Florida Civil Rights Act.
- A jury awarded Khatabi $81,028 in compensatory damages and $750,000 in punitive damages on unallocated claims; the district court reduced the total award by applying Title VII's small-employer cap.
- +2 more key facts with a free trial
Why it matters
This is the Eleventh Circuit's clearest post-Bradshaw statement that Florida Civil Rights Act damages stack on top of Title VII damages when a jury returns an unallocated verdict — producing a potential $400,000… — full analysis with a trial
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