Benson v. Sanford Health (Summary)

EMPLOYMENT DISCRIMINATION

Benson v. Sanford Health, No. CIV 08-4072 (D.S.D. Dec 16, 2011)

The U.S. District Court for the District of South Dakota denied a physician’s motion for a new trial on her gender discrimination and negligent infliction of emotional distress claims against a medical center. The court determined that the physician was not entitled to a new trial on her gender discrimination claim because she failed to provide evidence that her working conditions were made so intolerable that a reasonable person would have deemed resignation the only reasonable alternative.

A jury had rendered a verdict in favor of the physician on her claim of negligent infliction of emotional distress, but awarded no damages. Ruling that the damages award was not internally consistent with the liability verdict and finding no prejudice, mistake, or complete disregard of law and evidence in the jury’s verdict, the court denied the physician’s motion for a new trial on that claim as well.