Browne v. Signal Mountain Nursery, L.P.
Plaintiff Yvonne M. Browne sought a new trial after an unfavorable jury verdict in her hostile work environment case against Signal Mountain Nursery and its owners, David and Laurel Steele. Her motion was based on several alleged judicial errors, primarily challenging the court's jury instruction on the definition of a "supervisor" for Title VII vicarious liability. Other grounds included rulings on evidence concerning her prior sexual behavior, employment applications, and alleged theft, as well as procedural issues with voir dire and a Batson challenge. The District Court meticulously reviewed each argument, ultimately denying the motion for a new trial. The court affirmed its interpretation of "supervisor" based on the authority to effect tangible employment actions and upheld its discretionary evidentiary and procedural decisions, finding no substantial prejudice to the plaintiff.