U.S. Court of Appeals for the Third Circuit
Patricia Holmes v. American HomePatient, Inc
August 27, 2026
Summary
The Court upheld the finding that American HomePatient could be liable for punitive damages because sufficient evidence supported the jury’s rejection of the employer’s good-faith defense. It held that the $20 million punitive award was excessive, but concluded that a 4:1 ratio was constitutionally permissible given the intentional and repeated racial harassment, the company’s conduct, and its size, requiring a $2 million award. The Court also affirmed the attorney-fee award because Holmes did not establish reasonable market rates.