- 523 U.S. 208
OCTOBER TERM, 1997
HETZEL v. PRINCE WILLIAM COUNTY, VIRGINIA, ET AL.
ON PETITION FOR WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT
No. 97-954. Decided March 23,1998
A jury awarded petitioner $750,000 on her claims against respondent county under Title VII of the Civil Rights Act of 1964, but the District Court reduced the damages to $500,000. The Fourth Circuit affirmed the liability finding, but set aside the damages award as grossly excessive and remanded for recalculation. The District Court then awarded petitioner $50,000. She filed a motion for a new trial in which she declined the award, arguing that, in reducing her damages, the Fourth Circuit had effectively offered her a remittitur, which entitled her to a new trial under the Seventh Amendment's guarantee of a jury trial. The District Court agreed, concluding that when a court finds a jury's verdict excessive and reduces it, the plaintiff has a right either to accept the reduced award or to have a new trial on the damages issue. The Fourth Circuit then granted respondents' mandamus petition and stayed the scheduled retrial, noting that its prior decision had ordered the District Court to recalculate the damages "and to enter final judgment thereon."
Held: The Fourth Circuit violated petitioner's Seventh Amendment right to a jury trial. Because the Amendment prohibits the reexamination of facts determined by a jury, a court has no authority, upon a motion for a new trial, "according to its own estimate of the amount of damages which the plaintiff ought to have recovered, to enter an absolute judgment for any other sum than that assessed by the jury." Kennon v. Gilmer, 131 U. S. 22, 29. In determining that the evidence did not support the jury's general damages award and in ordering the District Court to recalculate the damages, the appeals court imposed a remittitur. The District Court correctly afforded petitioner the option of a new trial when it entered judgment for the reduced damages.
Certiorari granted; reversed.
A jury in the Eastern District of Virginia found for petitioner Hetzel on her claims against respondent County of Prince William under Title VII of the Civil Rights Act
of 1964, 42 U. S. C. § 2000e et seq., and Rev. Stat. § 1979, 42 U. S. C. § 1983. The District Court reduced the damages from $750,000 to $500,000, on the grounds that one of the claims supporting the award was legally insufficient. On respondents' appeal to the Court of Appeals for the Fourth Circuit, that court affirmed the finding of liability, but held that the damages award was grossly excessive because it was unsupported by the limited evidence of harm presented at trial. Hetzel v. County of Prince William, 89 F.3d 169, cert. denied, 519 U. S. 1028 (1996). The court "set aside the damage award and remand[ed] the case to the district court for the recalculation of the award of damages for emotional distress." 89 F. 3d, at 173.
On remand, the District Court recalculated the damages and awarded petitioner $50,000. Petitioner filed a motion for a new trial in which she declined the award. She argued that in reducing her damages, the Court of Appeals in effect had offered her a remittitur, and that she was therefore entitled to a new trial under the Seventh Amendment's guarantee of a right to trial by jury. Respondents agreed that the Court of Appeals' decision functioned as a remittitur, but contended that the decision did not allow petitioner the option of a new trial. In a memorandum opinion, the District Court determined that although the Court of Appeals' mandate clearly reversed the judgment and remanded for recalculation of damages, it did not address the Seventh Amendment issue, which had not arisen until petitioner rejected the recalculated damages award and sought a new trial. Concluding that Circuit precedent was clear that when a court finds a jury's verdict excessive and reduces it, the plaintiff has a right either to accept the reduced award or to have a new trial, the court granted petitioner's motion for a new trial on the issue of damages.
Respondents petitioned the Court of Appeals for a writ of mandamus, contending that the District Court did not have authority under its prior decision to order a new trial. In