Teutscher v. Woodson

Teutscher v. Woodson (9th Cir. 13-56411 8/26/16) Retaliatory Discharge Remedies/State Law & ERISA



The panel reversed the district court’s award of front pay and reinstatement as equitable remedies under the Employee Retirement Income Security Act for a retaliatory discharge after the plaintiff had already sought and been awarded by a jury front pay damages to compensate for the same harm.



The plaintiff went to trial against his former employer on retaliatory discharge claims under both state law and ERISA. The jury awarded him lump-sum damages on his state law claims, and the district court then entered judgment on his ERISA claim. Even though the jury had been instructed to include front pay in its damages award, the district court granted the plaintiff additional equitable remedies consisting of reinstatement as well as front pay until reinstatement occurred.



The panel held that the equitable front pay award conflicted with the jury’s front pay award in violation of the Seventh Amendment right to a jury trial. In addition, although the reinstatement remedy did not necessarily conflict with the fact findings implicit in the jury’s verdict, it nevertheless was improper because the plaintiff waived that relief when he elected to seek the duplicative front pay remedy from the jury.



Judge M. Smith concurred in the judgment. However, he disagreed with the majority’s Seventh Amendment analysis. Judge M. Smith would hold instead that the district court’s equitable remedy was an abuse of discretion because the district court did not give reasons why additional equitable relief was appropriate after the jury had already compensated the plaintiff for the monetary harm he suffered.

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