## Facts

- Adrienne Gatti worked for Community Action Agency of Greene County, Inc., ultimately serving as Head Start Director.
- Edward Daly, the agency’s Executive Director, supervised Gatti and had involvement in the events leading to her discharge.
- At trial, Gatti presented evidence that Daly made age-related remarks and expressed a preference for younger employees (including statements about needing “new blood”).
- Gatti contended Daly marginalized her, undermined her authority, and subjected her to age-based disparagement, creating a hostile work environment.
- Community Action asserted performance- and program-related reasons for the termination; Gatti argued those reasons were pretext for age discrimination.
- The Head Start program operated under federal regulations contemplating involvement of a parent Policy Council in major program decisions.
- A jury found for Gatti on age discrimination claims under the ADEA and New York State Human Rights Law and awarded $181,761 for lost wages and emotional distress/mental anguish.
- After judgment, defendants sought judgment as a matter of law or a new trial and challenged costs; Gatti sought attorney’s fees and pre- and post-judgment interest.

## Issues

1. Whether defendants were entitled to judgment as a matter of law under Fed. R. Civ. P. 50(b) because the evidence was legally insufficient to support the jury’s age-discrimination verdict.
2. Whether a new trial was warranted under Rules 50(c) and 59(a) because the verdict was against the weight of the evidence or otherwise unjust.
3. Whether the judgment should be altered under Rule 59(e) to strike or apportion costs despite plaintiff’s prevailing-party status.
4. Whether, and in what amounts, plaintiff was entitled to attorney’s fees and pre- and post-judgment interest following the verdict.

## Decision

- The Rule 50(b) motion for judgment as a matter of law was denied because the record contained sufficient evidence for a reasonable jury to find age-based intent and pretext.
- The motion for a new trial under Rules 50(c) and 59(a) was denied because the verdict was not seriously erroneous and the disputes largely turned on credibility determinations for the jury.
- The Rule 59(e) motion to strike or apportion costs was denied because plaintiff was the prevailing party and defendants did not show a sufficient basis to overcome the presumption favoring costs.
- Plaintiff’s motion for attorney’s fees and costs was granted as modified, with reductions for excessive, redundant, or inadequately supported time and adjustments to reasonable market rates.
- Plaintiff’s motion for pre- and post-judgment interest was granted as modified, applying federal standards for post-judgment interest and making appropriate adjustments to calculations.

## Legal Principles

- Rule 50(b) relief is appropriate only when, viewing the evidence favorably to the nonmovant, there is a complete absence of evidence supporting the verdict or the evidence overwhelmingly favors the movant.
- A new trial under Rule 59(a) is warranted only when the verdict is seriously erroneous or would result in a miscarriage of justice; courts should not substitute their judgment for the jury on credibility disputes.
- Under Rule 54(d), costs are presumptively awarded to the prevailing party, and the presumption is overcome only by a sufficient equitable showing.
- Prevailing plaintiffs under the ADEA may recover reasonable attorney’s fees; courts calculate fees using a lodestar approach and may reduce hours and adjust rates to reflect reasonable billing judgment and local market conditions.
- Pre-judgment interest may be awarded in ADEA cases to compensate for the time value of lost wages; post-judgment interest is governed by 28 U.S.C. § 1961.

## Conclusion

The court left the jury’s age-discrimination verdict and damages award intact, denied defendants’ post-trial attempts to overturn the outcome or reduce costs, and awarded plaintiff attorney’s fees and interest subject to court-ordered reductions and calculation adjustments.


Gatti v. Cmty. Action Agency of Greene Cnty., Inc., 263 F. Supp. 2d 496 (N.D.N.Y. 2003)