The dispute centers on Jennifer Guerrero, a field nurse for Constellation Health Services, who alleged that her employer terminated her in August 2021 shortly after she requested leave for a high-risk pregnancy. The jury found Constellation and its HR director, Nicole Sturtz, liable for disability and sex discrimination under the Americans with Disabilities Act, Title VII, and the Pregnancy Discrimination Act, as well as sex discrimination under the New York State Human Rights Law.
The jury awarded Guerrero $1,050,000 in total damages, including $420,000 in back pay, $30,000 in non-economic compensatory damages, and $600,000 in punitive damages. However, the jury rejected her claim for disability discrimination under the NYSHRL, creating a legal inconsistency that the court addressed in its post-trial order.
Judge Orelia E. Merchant granted Guerrero’s motion to amend the judgment under Rule 59(e) regarding the NYSHRL disability claim. The court reasoned that because the NYSHRL casts a wider net than the ADA and the two statutes are interpreted coextensively, it was a clear error for the jury to find liability under the federal law but not the state law. The judgment was amended to reflect a finding in favor of Guerrero on the NYSHRL disability discrimination claim.
The court denied Guerrero’s request for a new trial on damages, finding the jury’s $30,000 emotional distress award reasonable given the lack of medical corroboration for her alleged psychological injuries. The court also upheld the jury’s decision to award zero punitive damages against Sturtz individually, noting that individual liability does not mandate punitive damages if the jury finds the individual did not act with reckless indifference.
However, the court granted the defendants’ motion for remittitur on the remaining damages, finding the awards excessive. The back pay award was reduced from $420,000 to $7,500. The court determined Guerrero was not entitled to back pay for the period she was medically unable to work due to her pregnancy complications and found her entitled to only one month of back pay after her medical clearance.
The punitive damages award was slashed from $600,000 to $50,000. The court applied the statutory cap for ADA and Title VII claims, reducing the combined federal punitive and compensatory damages to $300,000. It then applied constitutional "Gore factors," finding the defendants' conduct lacked the high degree of reprehensibility required to support the original award, particularly in the absence of violence, deceit, or repeated misconduct.
Guerrero must elect by May 1, 2026, whether to accept the reduced damages of $87,500 total or demand a new trial limited to the issue of damages.