Landgraf v. USI Film Products

Background

A woman who worked overnight at a plastics plant sued her employer for repeated sexual harassment after quitting and filing an EEOC charge. A trial judge found harassment but not a constructive discharge, so under pre-1991 Title VII law she received no money damages. While her appeal was pending, Congress passed the Civil Rights Act of 1991, which added compensatory and punitive damages and a right to jury trial for some Title VII claims.

Reasoning

The Court addressed whether the 1991 damages and jury-trial rules apply to cases already pending when the law was enacted. It examined the statute’s text and legislative history and relied on a long-standing presumption that laws imposing new liabilities do not run backward unless Congress clearly says so. The Court treated the jury right as procedural but tied it to damages, and held compensatory and especially punitive damages would impose new legal consequences on past conduct. Finding no clear congressional statement to apply §102 retroactively, the Court declined to apply it to this pending appeal.

Real world impact

People with discrimination cases already finally tried before November 21, 1991, generally cannot seek the new damages or demand a jury under §102. Employers will not face added damages liability for conduct before the Act. The decision leaves open that Congress could change the rule or that different procedural provisions might apply in other post-enactment trials.

Dissents or concurrances

A concurring opinion agreed with the judgment but urged a stricter textual approach; a dissent argued the statute’s effective-date language supports applying §102 to pending cases.