Barati v. Metro North Railroad
The Federal Rail Safety Act permits damages for emotional distress. In 2008, the plaintiff, Andrew Barati, allegedly followed his employer's instructions to lower the load of his jack, and he crushed a toe. Barati reported the injury. The defendant employer, Metro North Railroad Co., allegedly disciplined and discharged Barati. Barati sued Metro North, alleging that Metro North violated the Federal Rail Safety Act and the Federal Employer Liability Act. A jury concluded that Barati was 60 percent negligent and awarded Barati $50,000, which the court reduced to $20,000. The jury also awarded $41,778 in compensatory damages and $1 million in punitive damages. The court reduced the punitive damages to $250,000, as a result of a statutory cap under the Federal Rail Safety Act. Metro North moved for a new trial and judgment as a matter of law. A jury reasonably could have concluded that Metro North's conduct, when it disciplined a worker who reported an injury allegedly caused by inadequate training and lighting, was "reprehensible." The District Court rejected the defendant's claim that the ratio of nearly 141-to-1 between punitive damages and compensatory damages was excessive. The actual ratio was about 6-to-1, which did not provide cause for concern. Metro North failed to persuade the court that manifest error required a new trial. Although Metro North objected to the summation of the plaintiff's attorney, the attorney did not mischaracterize facts. The attorney's claim that the evidence established that Metro North exhibited reckless disregard did not elicit a contemporaneous objection and was not improper. Ruling on an issue of apparent first impression, the District Court rejected Metro North's argument that the Federal Rail Safety Act did not permit damages for emotional distress. Metro North's argument that compensatory damages were restricted to itemized special damages was contrary to the plain meaning of statutory language. The District Court denied Metro North's motion for a new trial and judgment as a matter of law. In a separate memorandum, the court approved hourly rates of $525 for Attorney Charles Goetsch and $375 for Attorney Scott Perry and awarded attorneys' fees in the amount of $273,536.