Ramirez v. Wynn Las Vegas, LLC

District Court, D. Nevada·Decided July 29, 2025·No. 2:19-cv-01174·Unknown

Opinion

TIARE RAMIREZ, Case No.: 2:19-cv-01174-APG-EJY

Plaintiff Order on Post-Trial Motions

v. [ECF Nos. 174, 175, 179, 183, 188, 189, 190]

Defendant

A jury awarded plaintiff Tiare Ramirez $321,200 in lost wages and benefits on her claim of Family Medical Leave Act (FMLA) interference against defendant Wynn Las Vegas, LLC. The jury did not find Wynn liable on Ramirez’s Americans with Disabilities Act (ADA) discrimination claim and I granted Wynn’s motion for judgment as a matter of law on her negligent hiring, training, and supervision claims. Both parties now bring various post-trial motions. Wynn moves for remittitur or a new trial on damages, moves for Rule 37 sanctions against Ramirez’s counsel, renews its motion for judgment as a matter of law on the FMLA claim, and submits a bill of costs. Ramirez moves for a new trial on her ADA discrimination claim and on her negligent hiring, training, and supervision claims. She also moves for equitable relief, statutory damages, attorneys’ fees, and costs. The parties are familiar with the facts, so I repeat them here only as necessary to decide the motions. For the reasons described below, I grant Wynn’s motion for remittitur or new trial. I also grant in part Ramirez’s motions for statutory damages, attorneys’ fees, and costs. I deny the other motions. A. The evidence presented at trial does not support the jury’s verdict, so Wynn is entitled to a new trial on damages unless Ramirez accepts remittitur. Wynn argues that the jury’s award of $321,200 cannot be sustained by the evidence

presented at trial. It asserts that to reach that number, the jury must have either failed to offset Ramirez’s lost wages by her earnings over the relevant time period or awarded damages for lost benefits, for which no evidence was presented. Ramirez responds that the jury was permitted to ignore her subsequent earnings and that there was evidence of lost benefits, particularly the Wynn employees’ collective bargaining agreement (CBA). If, after viewing the evidence in the light most favorable to Ramirez, I conclude that the jury awarded excessive damages, I may order a new trial on damages or deny the motion conditioned on Ramirez’s acceptance of a remittitur. Oltz v. St. Peter’s Cmty. Hosp., 861 F.2d 1440, 1452 (9th Cir. 1988). I may order a new trial even if substantial evidence supports the jury’s verdict on liability where the damages award is excessive. Id.; Seymour v. Summa Vista

Cinema, Inc., 809 F.2d 1385, 1387 (9th Cir. 1987) (“Where there is no evidence that passion and prejudice affected the liability finding, remittitur is an appropriate method of reducing an excessive verdict.”), as amended by Seymour v. Summa Vista Cinema, Inc., 817 F.2d 609 (9th Cir. 1987). “A remittitur must reflect the maximum amount sustainable by the proof.” Oracle Corp. v. SAP AG, 765 F.3d 1081, 1094 (9th Cir. 2014) (quotation omitted). The FMLA limits a successful employee’s recovery to “any wages, salary, employment benefits, or other compensation denied or lost to such employee by reason of the violation.” 29 U.S.C. § 2617(a)(1)(A)(i)(I). Punitive damages and damages for emotional distress are not recoverable. Farell v. Tri-County Metro. Transp. Dist. of Or., 530 F.3d 1023, 1025 (9th Cir. 2008). Back pay for lost wages is calculated by “measuring the difference between actual earnings for the period and those which she would have earned” absent Wynn’s FMLA interference. Gotthardt v. Nat’l R.R. Passenger Corp., 191 F.3d 1148, 1158 (9th Cir. 1999). Benefits such as medical and life insurance are compensable “if the plaintiff has purchased

substitute insurance coverage or has incurred uninsured, out-of-pocket medical expenses for which he or she would have been reimbursed under the employer’s insurance plan.” Galindo v. Stoody Co., 793 F.2d 1502, 1517 (9th Cir. 1986).1 Awards for lost insurance coverage rather than expenses are “simply not a monetary benefit owing to the plaintiff” and including them “would make a plaintiff more than whole.” Id. Ramirez presented evidence that she earned an average of $28 per hour in wages and tips. And she testified that she would have worked full time after she returned from her medical leave. Based on this evidence, her counsel argued that she would have earned $301,280 from the date when Wynn suspended her to the cutoff date of December 31, 2022. ECF No. 164 at 56-57 (multiplying 28 x 40 hours x 269 weeks).2 Wynn asserts, and Ramirez does not contest, that

Ramirez’s actual earnings at other jobs over that period were $280,802.16 as reflected by her tax

1 Ramirez argues that I should not follow Galindo because it articulated this standard in the context of an unfair union representation suit. However, the Ninth Circuit also applied this damages calculation in a Title VII case. See EEOC v. Farmer Bros. Co., 31 F.3d 891, 902 (9th Cir. 1994). And other district courts have applied this standard to damages under the FMLA. See Zisumbo v. Convergys Corp., No. 1:14-cv-00134, 2020 WL 3546794, at *7 (D. Utah, June 30, 2020); Bowyer v. Dish Network, LLC, No. 08-1496, 2010 WL 1610112, at *7-8 (W.D. Penn., Apr. 20, 2010); Sherman v. AI/FOCS, Inc., 113 F. Supp. 2d 65, 68, 76 (D. Mass. 2000). Ramirez does not provide a compelling reason why her benefits damages should be calculated differently and does not point to any case where a court allowed damages for insurance coverage rather than out-of-pocket expenses. 2 Although Ramirez was not regularly working 40 hours per week prior to her termination at Wynn, she testified that she worked full time in her subsequent position at Caesar’s Palace and the jury could have reasonably inferred that she would have worked full time at the Wynn after returning from her medical leave. See ECF No. 157 at 86. documents.3 The jury was instructed to reduce any lost wages award by the amount Ramirez earned or could have earned. ECF No. 165 at 33. Ramirez testified that in addition to her lost wages she also lost her benefits, specifically her seniority and insurance. ECF No. 157 at 22, 25-26. Although she stressed that insurance

was very important to her family and that seniority is important with regards to hours and protecting against layoffs, she did not offer any testimony explaining what the value of these benefits should be or expenses she incurred due to losing them. To the extent seniority affects the number of hours or shifts Ramirez receives, its value is incorporated in the lost wages calculation, which assumed 40 hours of work per week. Ramirez’s counsel argued at closing that her lost benefits “were seniority and what-not,” and suggested a value of $500 per month. ECF No. 164 at 57. But there is no testimony or evidence to support this amount. And, as Wynn notes in its motion for sanctions, Ramirez did not disclose that she was seeking damages for lost benefits prior to trial. Ramirez argues that the CBA was included in evidence and the jury may have reviewed the benefits tables to come up with their final award. But Galindo and similar

cases make clear that absent a showing of actual expenses, simply paying Ramirez the money that would have gone to a health plan would leave her “more than whole.” 793 F.2d at 1517.4

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