Appeal from the United States District Court
for the Eastern District of Tennessee at Knoxville.
No. 3:14-cv-00397—Pamela Lynn Reeves, District Judge.
Argued: December 1, 2017
Decided and Filed: January 24, 2018
Before: DAUGHTREY, MOORE, and SUTTON, Circuit Judges.
KAREN NELSON MOORE, Circuit Judge. Plaintiffs who successfully prove that they
were fired in violation of Title VII of the Civil Rights Act of 1964 (“Title VII”) are
presumptively entitled to back pay for the amount they would have earned had they not been
unlawfully terminated. Such awards are intended to compensate fully plaintiffs for the wrongs
that they suffered. For the same reason, an award of prejudgment interest on the back pay owed
is also nearly always appropriate. We conclude from these principles that a district court must
grant a motion for a new trial as to damages when a jury awards back pay to a Title VII plaintiff
in an amount that is substantially less than the damages to which he is indisputably entitled.
Once damages are calibrated correctly, the district court should also make an effort to align its
award of prejudgment interest (if such interest is requested and warranted) with Title VII’s
remedial goals. Because the district court failed to take those steps here, we REVERSE and
REMAND for further proceedings consistent with our opinion.