182297P.pdf   03/18/2019  Adrian Bryant  v.  Jeffrey Sand Company
   U.S. Court of Appeals Case No:  18-2297
   U.S. District Court for the Eastern District of Arkansas - Little Rock   
   [PUBLISHED] [Kelly, Author, with Benton and Melloy, Circuit Judges] 
   Civil Case - racial hostile work environment. On appeal from jury verdict 
   for nominal compensatory and punitive damages, the award of punitive 
   damages is supported by the record, as the jury could have reasonably 
   concluded that Jeffrey Sand exhibited reckless indifference to Bryant's 
   rights; the claims under 42 U.S.C. sec. 1981 were timely under the 
   four-year statute of limitations, as the continuing violation rule applies 
   to punitive and compensatory damages and one act occurred within the 
   statutory period; award of $250,000 in punitive damages does not violate 
   due process as excessive or disproportionate in light of the degree of 
   reprehensibility of Jeffrey Sand's conduct, the indignities suffered even 
   as compared to the small amount of economic damages, and lack of a 
   statutory cap under section 1981. The district court did not abused its 
   discretion in awarding attorneys fees based on a lodestar rate of $350 per 
   hour.