The opinion of the court was delivered by: Ambrose, Senior District Judge
Pending is Defendant‟s Motion for Judgment and/or New Trial Pursuant to Fed. R. Civ. P. 50 and 59 and/or for Remittitur. (Docket No. 63). In its Motion, Defendant requests judgment as a matter of law pursuant to Federal Rule of Civil Procedure 50, or a new trial pursuant to Federal Rule of Civil Procedure 59. Defendant also requests, in the alternative, remittitur on damages awarded. Plaintiff filed a Brief in Opposition. (Docket No. 66). After a careful review of the submissions of the parties, Defendant=s Motion is denied in its entirety.
The factual and procedural details of this case are well known to the parties, and I need not repeat them in detail here. In short, Plaintiff, Tonka Crosby (A Plaintiff@ ), initiated this action against Defendant State Correctional Institution at Greensburg (A Defendant@ or A SCI Greensburg@ ), alleging retaliation in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. ' 2000e, et seq. (A Title VII@ ) and a pendent state claim under the Pennsylvania Human Relations Act, 43 Pa. Stat. ' 951, et seq. (A PHRA@ ). Specifically, Plaintiff contended that she was subject to a hostile work environment in retaliation for her having filed a prior charge of discrimination with the Equal Employment Opportunity Commission ("EEOC") and the Pennsylvania Human Relations Commission ("PHRC"). Defendant denied that it created a hostile work environment and denied any retaliation for the prior EEOC and PHRC claims.
A jury trial began in this case on November 1, 2010, and concluded on November 4, 2010. Defendant made Rule 50 motions on November 2, 2010, after the close of Plaintiff=s case, and on November 3, 2010, after the close of its case. Both of Defendant=s Rule 50 motions were denied. At the conclusion of the trial, the jury returned a verdict in favor of Plaintiff. The jury awarded Plaintiff compensatory damages in the amount of $100,000.
On December 1, 2010, Defendant filed the instant Motion for Judgment and/or New Trial Pursuant to Fed. R. Civ. P. 50 and 59 and/or for Remittitur and brief in support. (Docket Nos. 63, 64). Plaintiff filed her Brief in Opposition on December 8, 2010. (Docket No. 66). Defendant=s Motion is now ripe for my review.
Rule 50(b) of the Federal Rules of Civil Procedure provides that a district court Amay grant a renewed motion for judgment as a matter of law if 'there is no legally sufficient evidentiary basis for a reasonable jury to have found for' the prevailing party. Fed. R. Civ. P. 50(b). The 'legally sufficient evidentiary basis' has also been characterized as a 'minimum quantum of evidence,' Keith v. Truck Stops Corp., 909 F.2d 743, 745 (3d Cir.1990), or even as 'any rational basis for the verdict.' Bhaya v. Westinghouse Elec. Corp., 832 F.2d 258, 259 (3d Cir.1987)." PXRE Corp. v. Terra Nova Ins. Co. Ltd., 76 F. App=x 485, 489 (3d Cir. 2003) (quoting Olefins Trading v. Han Yang Chem. Corp., 9 F.3d 282, 288 (3d Cir. 1993)). The evidence must be viewed in the light most favorable to the non-moving party. Id.(citing Mosley v. Wilson, 102 F.3d 85, 89 (3d Cir.1996)).
The decision to grant a new trial is committed to the sound discretion of the district court. Montgomery Ward & Co. v. Duncan, 311 U.S. 243, 251 (1940); U.S. v. Schiffer, 836 F. Supp. 1164, 1169 (E.D. Pa. 1993). Pursuant to Rule 59, a motion for a new trial may be granted Afor any reason for which a new trial has heretofore been granted in an action at law in federal court.@ Fed. R. Civ. P. 59(a)(1). Such reasons include prejudicial erroneous judicial rulings or misconduct by opposing counsel. Olefins Trading, Inc., 9 F.3d at 289-90; Schiffer, 836 F. Supp. at 1169. In such cases, the court must assess whether an error was, in fact, committed, and whether the error was so prejudicial that denying a new trial would be inconsistent with substantial justice. Bhaya v. Westinghouse Elec. Corp., 709 F. Supp. 600, 601 (E.D. Pa. 1989), aff‟d, 922
F.2d 184 (3d Cir. 1990). Another reason for a new trial is where "the verdict is contrary to the great weight of the evidence." Roebuck v. Drexel Univ., 852 F.2d 715, 735-36 (3d Cir. 1988). In the latter case, a new trial is warranted only in those circumstances Awhere >a miscarriage of justice would result if the verdict were to stand.=@ Olefins Trading,9 F.3d at 289 (quoting Fineman v. Armstrong World Indus., Inc., 980 F.2d 171, 211 (3d Cir. 1992)). A new trial is never appropriate in cases involving only harmless error. Fed. R. Civ. P. 61.
When reviewing a jury verdict, Aa District Court . . . has an >obligation . . . to uphold the jury's award if there exists a reasonable basis to do so.= Motter v. Everest & Jennings, Inc., 883 F.2d 1223, 1230 (3d Cir.1989). >[T]he court may not vacate or reduce the award merely because it would have granted a lesser amount of damages.= Id. A new trial is warranted based >upon [a] showing that the jury verdict resulted from passion or prejudice.' Hurley v. Atlantic City Police Dep=t, 174 F.3d 95, 114 (3d Cir.1999) (quoting Dunn v. HOVIC, 1 F.3d 1371, 1383 (3d Cir.1993)). >[T]he ...