Martin Hall, an African-American, is a detective with the Clarksville, Tennessee Police Department. During his career, Hall has been subject to a variety of racially-oriented conduct. The conduct included other officers showing him an extremely offensive cartoon that represented African-Americans as embodying racist stereotypes, a statement by his lieutenant that he did not want Hall to ride with his friend and co-worker because he “didn’t want two black detectives riding together,” and a sergeant commenting when Hall came to the shooting range a few minutes late, “Damn nigger, showing up late.”
When Hall was working for the Criminal Intelligence Unit in late 2001 and early 2002, he came to work one day to find a noose hanging at the front of the building, toward the back wall where he had set up a computer work station. Hall believed that the noose was in retaliation for his complaining about the prior instances of racially-oriented comments and conduct. Hall also contended that he had been the target of low-level disciplinary action and a criminal investigation solely because he complained about the racist conduct in the Department.
After a trial, a federal court jury found that Hall had proved a racially hostile work environment as well as race-based retaliation. The jury awarded Hall $100,000 for the hostile work environment claim and $50,000 for the retaliation claim. The City appealed, contending there was no factual basis for the jury’s verdict.
The federal Sixth Circuit Court of Appeals affirmed the verdict. Noting that the Clarksville Police Department had previously been the subject of a successful federal court race discrimination claim, the Court found that the City “has presented no convincing argument that the jury erred in returning a verdict in favor of Hall in his hostile work environment claim. The jury was well within its province to find that Hall was subjected to retaliation for his protected Title VII activity. We conclude that the jury award is not excessive, did not result from bias or prejudice, and does not shock the conscience of the Court.”
Hall v. City of Clarksville, 2008 WL 1986636 (6th Cir. 2008).
This article appears in the August 2008 issue