Batavia Lodge No. 196, Loyal Order of Moose v. New York State Division of Human Rights, 35 N.Y.2d 143 (1974)
In cases of unlawful discrimination, particularly when intentional, the Commissioner of the Human Rights Division has broad discretion to award compensatory damages to aggrieved individuals, and the standard of evidence required to prove such damages is less stringent than under common-law principles.
Summary
This case addresses the scope of the New York State Division of Human Rights’ power to award compensatory damages for mental anguish resulting from discriminatory practices. Black complainants were denied service at a Moose Lodge bar while white nonmembers were served, and some were verbally abused. The Commissioner awarded each claimant $250 in compensatory damages, but the Appellate Division struck the award, requiring proof of out-of-pocket expenses. The New York Court of Appeals reversed, holding that the strong anti-discrimination policy of the state allows for a more flexible approach to awarding damages, especially in cases of intentional discrimination. The court emphasized that vindicating public policy against discrimination is a key consideration.
Facts
Black complainants were invited to a fashion show held on the premises of the Batavia Moose Lodge. Upon arrival, they were denied service at the bar, while white nonmembers attending the same fashion show were freely served. Some black complainants were also subjected to verbal abuse. The New York State Division of Human Rights investigated these incidents, finding sufficient evidence of unlawful discrimination.
Procedural History
The Commissioner of the Human Rights Division found unlawful discrimination and awarded $250 in compensatory damages to each claimant. The Appellate Division modified the Commissioner’s determination, striking the damage award, arguing that there was no evidence of out-of-pocket expenses or measurable damages. The New York Court of Appeals reversed the Appellate Division’s modification and reinstated the Commissioner’s award, emphasizing the broad powers of the Division and the state’s strong anti-discrimination policy.
Issue(s)
Whether the Commissioner of the Human Rights Division can award compensatory damages for mental suffering and anguish to individuals aggrieved by discriminatory practices without requiring proof of out-of-pocket expenses or measurable damages.
Holding
Yes, because the strong anti-discrimination policy of New York State grants the Commissioner more discretion in fashioning remedies than would be available under strict common-law principles, especially when the discriminatory act is intentional.
Court’s Reasoning
The Court of Appeals emphasized the importance of New York State’s policy against discrimination, citing previous cases such as Gaynor v. Rockefeller and Matter of Holland v. Edwards. The court noted that the Executive Law grants extensive powers to the Division of Human Rights to eliminate and prevent discriminatory practices. The court quoted Gaynor, supra, stating it was “ undoubtedly, the need for a programmatic enforcement of the anti-discrimination laws which prompted the Legislature to create the State Commission for Human Bights and to vest it with broad powers to eliminate specified ‘unlawful discriminatory practices’.” The court held that the Commissioner has the power to award compensatory damages for mental suffering and anguish, as established in Matter of State Comm. for Human Rights v. Speer. The court distinguished between common-law rights, which primarily provide private remedies, and statutory rights, which also vindicate public policy. Because this case involved a statutory right, a less stringent standard of evidence is required to prove compensatory damages. The court stated, “What we do hold is that due to the strong anti-discrimination policy spelled out by the Legislature of this State, an aggrieved individual need not produce the quantum and quality of evidence to prove compensatory damages he would have had to produce under an analogous provision, and this is particularly so where, as here, the discriminatory act is intentionally committed.” The court found the evidence in this case adequate to support the Commissioner’s determination and deemed the award reasonable under the circumstances.