Deborah H. Steele v. Superior Home Health Care of Chattanooga, Inc., and David Twombley - Concurring
Deborah H. Steele sued her former employer and supervisor, Superior Home Health Care of Chattanooga, Inc. and David Twombley, for sexual harassment under the Tennessee Human Rights Act (THRA), and for outrageous conduct and intentional infliction of emotional distress. A jury awarded Steele $1.2 million in compensatory and $60,000 in punitive damages, later remitted to $850,000 compensatory. On appeal, the Court affirmed the jury's finding of hostile environment sexual harassment against both defendants, concluding that Twombley was individually liable as an aider and abetter, and upheld the outrageous conduct claim against Twombley. However, the Court reversed the finding of quid pro quo sexual harassment against Superior due to a lack of evidence of tangible job detriment. The Court found no reversible error in the admission of evidence or jury instructions, and upheld the attorney's fees awarded against Twombley.