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Littlefield v. McGuffey

    Brief Fact Summary.

    Plaintiff was applying to rent an apartment from Defendant. Plaintiff and Defendant agreed that Plaintiff and some of her family members would reside in the apartment, and that Defendant would replace the carpet in the apartment, provided Plaintiff pay for the installation fee. Thereafter, Plaintiff’s daughter’s father went to see Defendant to pay for the installation fee. The father is a different race than Plaintiff. At that moment, Defendant began to become agitated and told the father, and subsequently, called Plaintiff at her work number, that the apartment was rented to someone else and that Plaintiff’s possessions were outside the apartment. Additionally, Defendant began harassing Plaintiff with notes and phone calls, causing her to become fearful for her family. Plaintiff brought suit against Defendant claiming violations of the Equal Opportunity in Housing provision of the Civil Rights Act of 1866, the Fair Housing Act, and intentional infliction of emotional distress under Illinois law. Plaintiff won in the trial court, and Defendant appealed.

    Synopsis of Rule of Law.

    Under federal civil rights violations and intentional infliction of emotional distress claims, damages should be sustained when the evidence supports liability and when the damages are reasonable related to the evidence and to similar cases. 

    Facts.

    On September 14, 1988, Susanne Littlefield, Plaintiff, a twenty-threeyear old, inserted an application to rent an apartment from Malcolm McGuffey, Defendant, who went by multiple aliases. The parties agreed that Littlefield, Sandra, Littlefield’s sister, and Littlefield’s two-year-old daughter, Shaunte, would occupy the apartment. The parties alsostipulated that Defendant would replace the carpet in exchange of Littlefield paying the cost of the installation.From that moment till September 27, Littlefield, her family, and friends painted the apartment and moved some possessions into it. On September 27, Bruce Collins, Shaunte’s father, went with Shaunte to see Defendant to pay for the carpet installation. Collins was not the same race as Littlefield. When Defendant met Collins, Defendant began to become agitated and told Collins that the apartment wasbeing rented to someone else. Defendant then called Littlefield to her work phone number and told her that the apartment was being rented to someone else, the locks had already been changed, and that Littlefield’s possession were removed. Littlefield began to become scared, upset, physically ill, and embarrassed. Littlefield began to cried and left work early. Subsequently, Defendant made numerous harassing phone calls to Littlefield and her sister where he was frequently pretended to be another person. Also, the phone calls were filled with racist epithets and other insults. Moreover, Defendant even left a note on Littlefield’s new residence door where he threatened to kill Collins and used racist slurs. Again, these incidents continued to make Littlefield extremely scared for herself and her daughter. Littlefield brought suit against Defendant for violations of the Equal Opportunity in Housing provision of the Civil Rights Act of 1866, the Fair Housing Act, and intentional infliction of emotional distress under Illinois law. At trial, Defendant contended that he refused to rent to Littlefield because she had a poor credit and rental history, not due to a racial reason. Nevertheless, Defendant did not provided evidence to support those claims. On the contrary, Littlefield provided evidence that she had adequate credit, Defendant did not obtain it, and that she was a good tenant in the past. The jury found in Littlefield’s favor and awarded her $50,000 in compensatory and $100,000 in punitive damages. Additionally, the trial court awarded Littlefield attorney’s fees of $140,000. Defendant appealed.

    Issue.

    Whether, in federal civil rights violations and intentional infliction of emotional distress claims, damages should be sustained when the evidence supports liability and when the damages are reasonable related to the evidence and to similar cases.

    Held.

    Yes, in federal civil rights violations and intentional infliction of emotional distress claims, damages should be sustained when the evidence supports liability and when the damages are reasonable related to the evidence and to similar cases.

    Discussion.

    The trial court properly founded in Plaintiff’s favor. In regards to Plaintiff’s claim for intentional infliction of emotional distress (IIED), Plaintiff is not required to show a physical injury. Thus, Defendant is incorrect in his assertion that that is a requisite element because Plaintiff only needs to show that his conduct was extreme and outrageous, where the conduct was intended or done with the knowing likelihood that emotional distress would ensue, and where the conduct actually caused severe emotional distress. Here, those elements were met. Additionally, Plaintiff’s evidence of her distress was not unduly prejudicial nor inflammatory because such evidence was a necessary component of proving her IIED claim. Instead, the evidence in support of Plaintiff’s discrimination claims was sufficient, especially because Defendant’s defense rested on an assessment of his credibility as opposed to solid evidence. Lastly, there is both legal and evidentiary grounds to sustain the damages against Defendant. Despite the fact that the Fair Housing Act imposed a cap on punitive damages at the time the case was filed, that cap was removed when the case matter was decided. Therefore, the trial court properly applied the law in effect at the time of the decision. Moreover, Plaintiff’s other discrimination claim never had a cap on punitive damages. Likewise, the trial court’s awards of compensatory damages and attorney’s fees were proper and not an abuse of discretion. Thus, the judgment is affirmed.


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