New York Law Review

State Commission for Human Rights v. Speer, 29 N.Y.2d 555 (1971): Scope of Damages Awardable by Human Rights Division

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State Commission for Human Rights v. Speer, 29 N.Y.2d 555 (1971)

The State Division of Human Rights possesses broad authority to award compensatory damages, including for mental anguish and suffering, in cases of unlawful discrimination, but the amount of such damages must be supported by evidence.

Summary

This case concerns the scope of the State Division of Human Rights’ power to award damages for mental anguish and suffering resulting from unlawful discrimination. The New York Urban League and John Gaynus filed a complaint alleging discriminatory rental practices. The Human Rights Appeal Board awarded compensatory damages. The Court of Appeals reversed the Appellate Division’s decision, holding that the Division of Human Rights could award damages for mental anguish, but the amount awarded must be supported by evidence. The matter was remitted to determine if the evidence justified the damage award.

Facts

  • The New York Urban League and John Gaynus, as Director of Operation Open City, filed a complaint with the State Commission for Human Rights.
  • The complaint alleged discriminatory rental practices by Edmund M. Speer, Jr., as Trustee, and others.
  • The Human Rights Appeal Board made an award that included compensatory damages for mental anguish and suffering.

Procedural History

  • The State Commission for Human Rights initially heard the complaint.
  • The Human Rights Appeal Board reviewed the Commission’s decision and made its own award.
  • The Appellate Division reversed the Appeal Board’s determination.
  • The New York Court of Appeals reversed the Appellate Division’s order and remitted the case.

Issue(s)

  1. Whether the State Division of Human Rights has the authority to award compensatory damages for mental anguish and suffering in discrimination cases?
  2. Whether the amount of damages awarded by the Division of Human Rights must be supported by evidence?

Holding

  1. Yes, because the State Division of Human Rights has broad authority to award compensatory damages to individuals who have suffered as a result of unlawful discriminatory practices.
  2. Yes, because any award for damages, including those for mental anguish and suffering, must be justified by the evidence presented.

Court’s Reasoning

The Court of Appeals, in reversing the Appellate Division, adopted the dissenting opinion from the lower court, which supported the Human Rights Division’s authority to award damages for mental anguish and suffering. The court emphasized that the purpose of the human rights laws is to eliminate discrimination, and this purpose is best served by allowing the Division to provide complete relief to victims of discrimination. However, the Court also stressed that any award of damages must be supported by evidence; the amount awarded must be reasonable and proportionate to the harm suffered. The Court remitted the case to the Appellate Division to determine whether the evidence justified the specific amount of damages awarded in this case. The dissenting judge believed that the Legislature never intended to allow the commission the power to award damages for pain, suffering and mental anguish since these claims often involved large sums of money and deprived the defendant of the right to a jury trial.

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