## Facts

- Susanne Littlefield applied to rent a two-bedroom apartment from landlord Malcolm McGuffey, paid a $280 security deposit, received a key, and began cleaning, painting, and moving items into the unit.
- McGuffey placed a fictitious payee on the deposit check and endorsed it using assumed names.
- The rental arrangement contemplated that Littlefield would live in the unit with her sister and child, and that McGuffey would install carpet after Littlefield paid installation costs.
- When Littlefield’s boyfriend, an African-American man and the father of her child, appeared to pay for carpet, McGuffey abruptly stated the apartment had been rented to someone else.
- McGuffey later told Littlefield the locks had been changed and her belongings removed, causing her fear, embarrassment, and physical illness.
- McGuffey then engaged in an extended course of harassment, using multiple aliases to place threatening and racially abusive calls to Littlefield and her family and leaving a racially charged death threat directed at the boyfriend.
- McGuffey denied racial discrimination and claimed he refused to rent due to Littlefield’s credit and rental history, but the jury heard evidence that he did not actually obtain credit information and that her credit and prior tenancy were adequate.

## Issues

1. Whether the evidence was sufficient to support liability under 42 U.S.C. § 1982, the Fair Housing Act (42 U.S.C. §§ 3604, 3613, 3617), and Illinois intentional infliction of emotional distress.
2. Whether the compensatory and punitive damage awards were supported by the record and free from improper jury influence.
3. Whether the district court abused its discretion in evidentiary rulings and jury instructions.
4. Whether the district court properly awarded attorney’s fees, denied an upward multiplier, and denied post-trial relief (JNOV/new trial).

## Decision

- The Seventh Circuit affirmed the judgment on the jury verdict for Littlefield on the federal housing discrimination claims and intentional infliction of emotional distress.
- The court held the record supported the jury’s finding that McGuffey denied housing because of race, as shown by the timing of the refusal after learning of the interracial relationship and by racially charged threats and harassment.
- The court upheld $50,000 in compensatory damages and $100,000 in punitive damages, finding sufficient evidentiary support and no basis to disturb the jury’s assessment.
- The court rejected challenges to evidentiary rulings and jury instructions, finding no abuse of discretion and no prejudice warranting reversal.
- The court affirmed the attorney’s fee award and the denial of a fee multiplier, concluding the district court acted within its discretion.
- The court affirmed denial of McGuffey’s post-trial motions seeking JNOV or a new trial.

## Legal Principles

- Intentional race discrimination in housing may be proven through circumstantial evidence, including suspicious timing, pretextual explanations, and racially hostile conduct connected to the housing decision.
- A defendant’s unsupported claim of non-discriminatory reasons may be rejected by the factfinder where contrary evidence supports an inference of pretext and discriminatory intent.
- Under Illinois law, intentional infliction of emotional distress requires extreme and outrageous conduct, intent or recklessness, and severe distress; repeated racist threats and intimidation can satisfy the standard.
- Compensatory damages for emotional distress and punitive damages for willful misconduct may be sustained where the evidence shows substantial harm and deliberate, aggravated wrongdoing; a defendant’s failure to present financial evidence can forfeit arguments for reducing punitive damages on ability-to-pay grounds.
- Trial courts have broad discretion over evidentiary rulings, jury instructions, and statutory fee awards in civil rights and fair housing cases; multipliers are not required absent exceptional justification.

## Conclusion

The Seventh Circuit upheld a jury verdict finding that a landlord denied housing because of an interracial relationship and then carried out a racially abusive campaign of threats and harassment, affirming liability under federal housing statutes and state tort law, as well as substantial compensatory and punitive damages and a lodestar-based attorney’s fee award without a multiplier.


Littlefield v. McGuffey, 954 F.2d 1337 (7th Cir. 1992)