Trainor v. HEI Hospitality

Lawrence Trainor (plaintiff) was 59 years old with a successful hospitality-management career when HEI Hospitality, LLC (HEI) (defendant) recruited Trainor to work as a senior vice president in HEI’s Connecticut office. However, due to his wife’s health problems, Trainor was unwilling to move from Massachusetts to Connecticut. To entice Trainor to take the position, HEI agreed that Trainor could work in the Connecticut office one day per week and work elsewhere the other days. Trainor took the position and received good performance reviews for the next two years. HEI then restructured its executive team and gave Trainor a choice: either relocate to Connecticut full-time or be demoted to the general manager of a Massachusetts hotel, a position that came with a substantial salary reduction. Through a lawyer, Trainor formally complained to HEI about the offer, claiming that HEI’s restructuring and offer were motivated by age discrimination. HEI responded by telling Trainor that his current position had been eliminated, leaving Trainor with the option of accepting the demotion or quitting. Trainor’s lawyer wrote HEI expressing concern about the latest events. HEI’s chief executive officer admitted that he felt pissed when he received the lawyer’s letter, and he gave Trainor until January 2 to accept the demotion offer. Instead of responding, on January 2, Trainor filed an age-discrimination complaint against HEI with the State of Massachusetts. Hours after HEI received Trainor’s age-discrimination complaint, it terminated Trainor, stating that the termination was because the demotion offer had expired. Trainor’s claim was eventually heard by a jury in federal district court. During the trial, Trainor and his wife both testified that Trainor had been emotionally distressed by the termination and the financial problems it caused. The jury found that HEI had not committed age discrimination but that it had knowingly retaliated against Trainor for complaining about age discrimination. The jury awarded Trainor back pay, front pay, and $1 million in emotional-distress damages. The district court reduced the emotional-distress award to $500,000, doubled all the damages because the retaliation was intentional, and entered judgment. HEI appealed.