Singh v. Memorial Sloan Kettering Cancer Center

Background

Manisha Singh sued Memorial Sloan Kettering Cancer Center, Sloan Kettering Institute for Cancer Research, Dr. N.V. Kishore Pillarsetty, and Dr. Steven M. Larson. After some claims were dismissed, the case went to trial on claims under Title VII of the Civil Rights Act of 1964, the New York State Human Rights Law, the New York City Human Rights Law, and New York tort law. Singh also proceeded on a civil-battery claim against Pillarsetty.

Singh alleged that Pillarsetty subjected her to unwanted sexual touching and that the defendants retaliated against her for reporting harassment. At trial, Singh sought damages for emotional distress and did not claim physical injuries. The jury found for Singh on the battery claim against Pillarsetty, awarding $50,000 in compensatory damages and $200,000 in punitive damages. The jury found for the defendants on all other claims.

Motion for a New Trial

Singh moved under Rule 59 of the Federal Rules of Civil Procedure for a new trial on the ground that the compensatory-damages award was inadequate and contrary to the weight of the evidence.

Because the battery claim arose under state law, the court applied New York’s standard for reviewing damages awards. Under that standard, an award is inadequate if it materially deviates from reasonable compensation. The court reviewed the trial evidence and compared the award with awards in New York cases involving similar injuries. It also explained that the jury’s damages determination was entitled to considerable deference and that Singh faced a high burden.

Court’s Analysis

The court concluded that the $50,000 award was not unreasonably low. The jury had found for the defendants on fourteen of the fifteen claims, so it could reasonably have limited compensation to emotional distress directly caused by the battery. The evidence also showed other possible sources of Singh’s emotional distress, including her prior abusive marriage and the loss of her employment.

The court further reasoned that the jury was entitled to decide which parts of Singh’s testimony and her mental-health providers’ testimony to credit. It could have found that some alleged symptoms were not proven or were not sufficiently connected to the battery. It also could have disbelieved some of Singh’s testimony about the extent, frequency, or duration of the touching. The court noted that the evidence supporting the battery claim consisted only of Singh’s testimony and was not so overwhelming that a larger award was required.

The court distinguished several cases cited by Singh because they involved additional physical injuries, economic harm, reputational harm, or more extensive harassment. It identified other New York cases with comparable battery-related damages awards and concluded that Singh’s award was consistent with reasonable compensation.

Disposition

Judge George B. Daniels denied Singh’s motion for a new trial on compensatory damages. The Clerk of Court was directed to close the motion and enter judgment in the action.