Third Circuit Reduces Verdict Against Linde Unit in Race-Bias Case to $2 Million

Court Slashes Verdict Against American HomePatient

A three-judge panel of the US Court of Appeals for the Third Circuit ruled on Thursday that the $20 million jury verdict against American HomePatient Inc., a Linde PLC subsidiary, was unconstitutionally excessive. The panel upheld a Pennsylvania district judge's post-trial reduction of the award and affirmed an alternative figure of $2 million, consisting of the original $1 million award doubled by the trial court. The appellate court found that the trial judge had correctly concluded the jury's verdict would breach the US Constitution's protections for defendants against excessive or arbitrary jury awards.

Conduct Described as "Exceedingly Reprehensible"

Despite reducing the damages, the Third Circuit panel emphasized the severity of the underlying conduct. The court described American HomePatient's behavior as "exceedingly reprehensible" and pointed to the company's failure to address a series of intentional discriminatory acts against a Black former worker. The case arose from a race-based harassment claim brought by the former employee. The ruling reflects the court's effort to balance recognition of the gravity of the workplace conduct with constitutional limits on jury awards.

Procedural Path and Significance

The dispute followed a multi-stage process in which a jury returned the original $20 million verdict, after which the district judge intervened to lower the damages. The Third Circuit's decision leaves the $2 million award in place while foreclosing reinstatement of the larger jury figure. The outcome illustrates how appellate courts apply constitutional excessiveness review to civil rights verdicts, potentially narrowing employer exposure in comparable discrimination cases.

Next Step in the Litigation

The ruling does not foreclose further proceedings; parties in race-bias verdicts reduced on constitutional grounds commonly seek en banc review or certiorari to the US Supreme Court. No such filing was identified in the available reporting.