An $811,264 award unravels - and a buried handbook clause couldn't stop the jury
A federal appeals court vacated an $811,264 retaliation verdict for a Black worker removed after a grooming-policy complaint, ordering a new trial.
The Eleventh Circuit's August 5, 2026 ruling shows how a large retaliation award can come undone on appeal, and how the handling of a hairstyle complaint can pull an employer back into court.
The worker was hired for a mailroom job at a Hyundai plant in Montgomery, Alabama. She wore her hair in locs. The security contractor that employed her, Dynamic Security, enforced a grooming policy that banned locs and similar styles for uniformed officers. She got the job after showing interviewers a photo of her hair in an "updo," which they approved.
On her first day, she arrived with her hair in locs and was sent home over it. She testified that a manager linked the policy to race, telling her that people at the plant "don't want African Americans wearing their hair like this." The next day she wore a hat, but a meeting with two managers grew tense. She testified that one manager warned her, "You're going to be a problem."
She filed a written discrimination complaint. Soon after, a district manager told her she could not return to work. She took her case to the EEOC in August 2017 and sued in October 2019, alleging race and pregnancy discrimination and retaliation under Title VII and Section 1981.
Only her Section 1981 retaliation claim reached a jury. It sided with her, awarding $85,200 in backpay, $214,864 for emotional pain and suffering, and $511,200 in punitive damages.
On appeal, the result was mixed. The court upheld the dismissal of every claim against the two Hyundai entities, and upheld the dismissal of the worker's Section 1981 race discrimination claim against Dynamic. But it revived her Title VII claims, ruling the trial court wrongly assumed she had received her EEOC right-to-sue letter when she said she never did. It also found the jury received a flawed instruction on the retaliation claim, which is why the verdict could not stand.
Two findings speak directly to HR teams. The court held that a general handbook acknowledgment did not waive the worker's right to a jury trial, because the form she signed never specifically mentioned that right. It also said the jury at the new trial should decide whether the company discriminated against her because of her race.
With the verdict vacated, nothing is finally decided. The case returns to the district court for a new trial.
