Littlefield v. McGuffey

Susanne Littlefield (plaintiff) agreed to rent an apartment from Malcolm McGuffey (defendant) for herself, her sister, and her two-year-old daughter, Shaunte. When Shaunte's father, Bruce Collins, who was of a different race than Littlefield, came to pay for carpet installation, McGuffey grew agitated and told Littlefield by phone that the apartment had been rented to someone else, her locks changed, and her belongings removed - news that left her scared, physically ill, and in tears. Afterward, McGuffey made repeated harassing calls to Littlefield and her sister filled with racist epithets, sometimes pretending to be someone else, and left a note at her new home threatening to kill Collins using racial slurs, leaving Littlefield fearful for herself and her daughter. Littlefield sued under federal fair-housing statutes and Illinois intentional-infliction-of-emotional-distress law; McGuffey claimed he'd refused to rent to her over poor credit and rental history but offered no supporting evidence, while Littlefield showed her credit was adequate, that McGuffey never actually checked it, and that she had a good rental history. A jury awarded her $50,000 compensatory and $100,000 punitive damages, and the trial court awarded $140,000 in attorney's fees; McGuffey appealed.