## Facts

- Jaymie Quigley, a low-income tenant using Section 8 vouchers, rented from Dale Winter, a private landlord with numerous rental properties in Sioux City, Iowa.
- Quigley alleged Winter subjected her to repeated unwanted sexual conduct and intimidation affecting her ability to use and enjoy her home.
- When showing Quigley a larger unit, Winter touched her arm and made a suggestive remark, which Quigley found frightening and degrading.
- Winter was reported to have entered Quigley’s home without prior notice.
- During an inspection, Winter followed Quigley and her minor sister into a bedroom, refused to leave when asked multiple times, and pressed his genital area against Quigley.
- Winter made late-night phone calls to Quigley while intoxicated.
- After Quigley asked about return of her security deposit, Winter touched her stomach and made a remark Quigley interpreted as implying the deposit depended on sexual conduct; Winter did not return the deposit.
- An investigator testified other similarly situated female tenants receiving housing assistance reported conduct consistent with Quigley’s complaints.

## Issues

1. Whether a landlord’s sexual harassment can constitute sex discrimination under the Fair Housing Act and Iowa Civil Rights Act under hostile-environment and quid pro quo theories, and whether the evidence supported the jury’s findings.
2. Whether Winter’s conduct also supported liability for coercion, intimidation, threats, or interference with housing rights under 42 U.S.C. § 3617 (and the state analogue).
3. Whether due process required reducing the jury’s $250,000 punitive damages award, and if so, to what amount.
4. Whether the district court abused its discretion by sharply reducing the requested attorney’s fees without an adequate lodestar analysis.

## Decision

- The court affirmed the judgment on liability, holding the evidence supported findings of hostile housing environment harassment, quid pro quo harassment, sex discrimination, and unlawful interference with housing rights.
- The court affirmed that punitive damages were available on the facts found by the jury.
- The court held the jury’s $250,000 punitive award (about 18:1 relative to compensatory damages) was constitutionally excessive, but the district court’s reduction to a 1.5:1 ratio was too low given the misconduct.
- The court modified the punitive damages award to $54,750 (a 4:1 ratio to compensatory damages).
- The court held the district court abused its discretion in awarding only $20,000 in attorney’s fees without sufficient lodestar reasoning and set attorney’s fees at $78,044.33.

## Legal Principles

- Sexual harassment by a housing provider can be actionable sex discrimination under the Fair Housing Act, including:
  - Hostile housing environment harassment that is sufficiently severe or pervasive to interfere with use and enjoyment of a dwelling.
  - Quid pro quo harassment conditioning housing benefits on sexual conduct.
- A pattern of harassment and economic pressure by a landlord may constitute “coercion, intimidation, threats, or interference” with fair-housing rights under 42 U.S.C. § 3617.
- Due process review of punitive damages considers reprehensibility, the punitive-to-compensatory ratio, and comparison to sanctions for similar misconduct; punitive awards generally should remain within single-digit ratios.
- In fee-shifting civil-rights cases, courts must apply a reasoned lodestar analysis (reasonable hours × reasonable rates) and explain substantial reductions with record-based findings.

## Conclusion

The Eighth Circuit upheld liability for landlord sexual harassment and interference with housing rights under federal and state fair-housing law, adjusted punitive damages to a constitutionally permissible 4:1 ratio to reflect seriousness and deterrence, and corrected the attorney-fee award because the district court did not adequately apply and explain the lodestar methodology.


Quigley v. Winter, 598 F.3d 938 (8th Cir. 2010)