First Circuit -- Sagun Tuli v. Brigham & Women's Hospital

Gender discrimination verdict upheld.


No requirement to seek internal remedy where formal remedy discouraged by supervisor and specific adverse employment action taken.

Within SOL, as it didn't tick until a formal presentation to hospital committee about hostile work environment.

Hearsay in as not for the truth of the matter asserted.

Holding claim in abeyance is not a formal waiver.

No error in denial of isolated incidents instruction.

Jury could reasonably find that ordered counseling was retaliation.

The formal presentation resuscitated earlier small incidents for purposes of causation assessment.

No error in jury construing negative evaluations as animus.

No error in jury finding defamatory statement reckless.

No abuse of discretion in denying remittitur for 1.6m verdict; parallel state claims allow the jury to bypass the federal damages limit.

No error in 1.3m fees.

Sagun Tuli v. Brigham & Women's Hospital,