Susanne Littlefield v. Malcolm McGuffey Susanne Littlefield v. Wally MacK Santa Maria Realty and Malcolm McGuffey
954 F.2d 1337 · Court of Appeals for the Seventh Circuit · 1992
Facts
Susanne Littlefield, a 23-year-old woman, applied to rent an apartment from Malcolm McGuffey in September 1988. She completed an application, paid a security deposit, and received a key, after which she and her family cleaned and painted the unit and moved in some belongings. On September 27, 1988, Littlefield's boyfriend, Bruce Collins, who was the father of her daughter, went to McGuffey to pay for carpet installation. Upon realizing Collins was not of the same race as Littlefield, McGuffey became agitated and denied her the apartment, claiming it was rented to someone else. McGuffey subsequently made numerous harassing, racist phone calls to Littlefield and her sister, using various personas and making degrading, threatening remarks. He also left a note on Littlefield's new residence threatening Collins's life with racist slurs. Littlefield suffered severe emotional distress, including hysteria, stomach upset, and fear for her daughter's safety. McGuffey denied the allegations, claiming Littlefield was a poor credit risk, but his claims were contradicted by witnesses.
Procedural history
Susanne Littlefield sued Malcolm McGuffey in the district court, where a jury found McGuffey liable and awarded compensatory and punitive damages. McGuffey moved for judgment notwithstanding the verdict and a new trial, which the district court denied. The district court then entered judgment, awarded attorney's fees, denied a fee multiplier, and imposed Rule-11 sanctions on McGuffey's attorneys. McGuffey appealed the judgment and attorney's fees, and Littlefield cross-appealed the denial of a fee multiplier to this court.
Issue
Did the district court err in its evidentiary rulings, jury instructions, damage awards (compensatory and punitive), and attorney's fees in a housing discrimination and harassment case, and did it err in denying a fee multiplier for contingent risk?
Holding
No, the district court's judgment and orders are affirmed, including the denial of the fee multiplier.
Rule
Under Illinois common law, intentional infliction of emotional distress does not require physical manifestation of emotional distress or the perpetrator's physical presence. A court applies the law in effect at the time of its decision unless doing so would result in manifest injustice, meaning the Fair Housing Amendment Act of 1988's removal of the punitive damage cap applies to cases decided after its effective date. Punitive damage awards under federal law (42 U.S.C. § 1982) are not capped, and a defendant challenging punitive damages bears the burden of introducing evidence of their financial worth. Attorney's fees are awarded to prevailing parties in federal claims, and the amount is largely within the trial court's discretion, not necessarily proportional to damages. A fee multiplier for contingent risk is appropriate only if the risk of losing was significant at the outset of the case, not due to a defendant's obstructive conduct.
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