HR Employee Wins $5 Million Verdict in Title VII Retaliation Case
Executive Summary
| Category | Amount |
| Non-Economic Damages | $75,000 |
| Punitive Damages | $5,000,000 |
| Total Verdict | $5,075,000 |
On January 29, 2026, a federal jury in Salt Lake City, Utah awarded $5,075,000 to a former human resources benefits generalist who claimed her employer, Bristol Hospice Holdings, Inc., terminated her in retaliation for filing a discrimination charge with the Utah Antidiscrimination and Labor Division. The jury found by a preponderance of evidence that Bristol Hospice retaliated against the plaintiff and awarded $5 million in punitive damages—reflecting a determination that the company acted with "malice or reckless indifference" toward the employee's protected rights under Title VII of the Civil Rights Act.
Case Information
Case Name: Graham v. Bristol Hospice Holdings, Inc.
Court: United States District Court for the District of Utah
Case Number: 2:21-cv-00754-TS-DBP
Presiding Judge: Senior Judge Ted Stewart
Verdict Date: January 29, 2026
Type: Title VII Retaliation
Parties
Plaintiff: Elizabeth Graham (a former HR Benefits Generalist at Bristol Hospice)
Defendant: Bristol Hospice Holdings, Inc., a hospice care provider headquartered in Salt Lake City, Utah. Founded in 2006, Bristol Hospice operates in multiple states and employs between 1,000 and 5,000 people, providing hospice and palliative care services.
Counsel
Plaintiff's Counsel:
April L. Hollingsworth, Hollingsworth Law Office, LLC (Salt Lake City, Utah)
Key Findings and Verdict
The jury returned a verdict in favor of the plaintiff on her Title VII retaliation claim, finding that Bristol Hospice terminated her employment because she engaged in protected activity—specifically, filing a discrimination charge with the Utah Antidiscrimination and Labor Division.
Damages Awarded:
Non-Economic Damages: $75,000
Punitive Damages: $5,000,000
Total: $5,075,000
The substantial punitive damages award indicates the jury found that Bristol Hospice met the heightened standard for such damages under Title VII—that the company acted with "malice or reckless indifference" to the plaintiff's federally protected rights.
During trial, the court denied Bristol Hospice's motion for judgment as a matter of law on the retaliation claim, finding sufficient evidence that the employer's stated reasons for termination were pretextual and that the plaintiff's protected activity was the real reason for her discharge. The court also granted the plaintiff's motion to exclude the Kolstad good-faith defense instruction regarding punitive damages.
Factual Background
The plaintiff worked as an HR benefits generalist at Bristol Hospice. According to the complaint filed in 2021, she initially complained that her supervisor—a payroll director—had subjected her to a hostile work environment. The company's vice president of human resources investigated the complaint but dismissed it, determining that the supervisor's behavior was "a one-time issue, not a general behavioral concern."
The plaintiff alleged that the problematic behavior continued despite this determination. Approximately a year later, another Bristol Hospice employee filed a complaint with the U.S. Equal Employment Opportunity Commission (EEOC), alleging that the same payroll director had harassed and discriminated against her based on age and gender.
As part of the investigation into her coworker's EEOC complaint, the plaintiff was interviewed and substantiated several of the allegations against the payroll director. Shortly thereafter—approximately one month later—the plaintiff filed her own discrimination charge with the Utah Antidiscrimination and Labor Division.
Following an unsuccessful mediation attempt, the plaintiff withdrew her charge "in an attempt to improve the atmosphere at work," according to court documents. Approximately two months after the mediation, Bristol Hospice terminated her employment.
The jury found that the termination constituted unlawful retaliation for her protected activity of filing the discrimination charge and corroborating her coworker's allegations.
Analysis and Implications
This verdict is notable for several reasons. First, the ratio of punitive damages to compensatory damages—approximately 67:1—reflects the jury's strong disapproval of the employer's conduct. While such ratios can invite post-trial scrutiny under BMW of North America v. Gore and State Farm v. Campbell, courts have upheld significant punitive awards in employment retaliation cases where the evidence demonstrates particularly egregious conduct.
Second, plaintiff's counsel April Hollingsworth emphasized in a statement that Bristol Hospice's executive vice president of human resources "intentionally refused to apply any of the company's own progressive discipline policies, which she wrote, when she terminated my client after she complained of discrimination." This allegation—that the decision-maker selectively ignored established company policy when terminating the plaintiff—likely contributed significantly to the punitive damages finding.
Third, the case underscores the risks employers face when employees participate in internal or external discrimination investigations. Under Title VII, retaliation claims protect not only employees who file their own charges but also those who participate in investigations of others' complaints. Here, the plaintiff both corroborated a coworker's allegations and filed her own charge—dual forms of protected activity that preceded her termination.
The timing between the protected activity and the adverse employment action was also significant. Courts have consistently recognized that close temporal proximity between protected activity and termination can support an inference of retaliation, though timing alone is typically insufficient to prove causation at trial.
Broader Context
Retaliation claims remain the most frequently filed charge with the EEOC, accounting for over half of all charges in recent years. As the EEOC has noted, retaliation can take many forms, including termination, demotion, denial of benefits, or other adverse actions that might deter a reasonable person from engaging in protected activity.
For employers, this verdict serves as a reminder that termination decisions involving employees who have recently engaged in protected activity—whether filing complaints, participating in investigations, or requesting accommodations—require careful documentation and adherence to established disciplinary procedures. Deviation from standard practices in such cases can support claims of pretext and significantly increase exposure to punitive damages.