Kolstad v. American Dental Association

Carole Kolstad (plaintiff), director of federal agency relations for the American Dental Association (defendant), sought a promotion to a newly open legislative-policy position, competing against Tom Spangler, who was ultimately selected by Dr. William Allen after an interview process. Kolstad sued under Title VII for gender discrimination, alleging the selection process was rigged for Spangler from the start, offering evidence the job description had been edited to essentially preselect him and that a supervisor, Wheat, had used sexually offensive language about women. A jury found discrimination and awarded Kolstad back pay, but the district court refused to instruct the jury on punitive damages, and the court of appeals upheld that ruling, requiring evidence of "egregious" employer conduct beyond mere intentional discrimination. The Supreme Court granted review.