Plaintiff Angelica Woods sued defendant James Wilson, former Director of the Department of Streets for the City of St. Louis, in the United States District Court for the Eastern District of Missouri raising a claim of First Amendment retaliation. Before the court is Wilson’s post-trial motion for judgment as a matter of law or, alternatively, for a new trial.
Statement of Facts
Woods was a long-time City employee who began working at the City’s tow lot in April 2020 as a clerk typist. Shortly after starting, Woods observed and reported various illegal activities at the tow lot, including the unlawful sale and transfer of vehicles. She reported these activities to her supervisors, City officials, and eventually the media.
After reporting these activities, Woods experienced harassment and retaliation from coworkers and supervisors who were part of what she called the “buddy system” – a group of people who either participated in the fraud or protected those who did. Woods was labeled a “snitch” and marginalized for refusing to participate in illegal activities.
In December 2020, Woods contacted KSDK reporters about the illegal activities at the tow lot. On February 4, 2021, KSDK published a news article and aired a newscast about improprieties at the tow lot, featuring anonymous quotes from Woods. The next day, February 5, 2021, Woods was fired by Wilson.
Legal Analysis
Motion for Judgment as a Matter of Law
Evidence of Pretext: The court found that Woods presented ample evidence of pretext for her termination, including inconsistencies in Wilson’s stated reasons for firing her and disparate treatment compared to other employees involved in workplace incidents.
Qualified Immunity: The court rejected Wilson’s claim of qualified immunity, finding that the right to be free from retaliation for protected speech was clearly established.
Punitive Damages: The court determined there was sufficient evidence to support submitting the issue of punitive damages to the jury, given Wilson’s awareness of Woods’ complaints and the timing of her termination.
Motion for New Trial
Evidentiary Rulings: The court found no errors in its evidentiary rulings that would warrant a new trial, including the admission of Woods’ pre-termination hearing recording and evidence of Wilson’s treatment of other employees.
Protected Speech: The court rejected Wilson’s argument that Woods’ complaints to supervisors and City officials were not protected speech, finding that reporting illegal activities was not part of her official job duties as a clerk typist.
Attorney’s Fees and Costs
The court granted in part and denied in part Woods’ motion for attorney’s fees and costs. It awarded a total of $233,673.60 in attorney’s fees and $2,694.41 in taxable costs, making reductions for work on unrelated claims and adjusting for non-taxable expenses.
The court denied Wilson’s motion for judgment as a matter of law and motion for new trial, and partially granted Woods’ motion for attorney’s fees and costs.
Schrag on Law 