Dallas Trial Court Upholds Maximum Damages Award of $300,000 Against SkyWest Airlines, Inc. in EEOC Sexual Harassment Suit

DALLAS – A federal judge has denied SkyWest Airlines, Inc.’s bid for a new trial and upheld an order that SkyWest pay a former parts clerk $300,000 in damages. The ruling came after the U.S. Equal Employment Opportunity Commission (EEOC) filed a lawsuit in which a federal jury found SkyWest liable for subjecting her to a sexually hostile work environment. The court further ordered injunctive relief for a three-year period. 

In November 2024, following a six-day trial, a federal jury awarded $2.17 million in damages against SkyWest for sexually harassing Sarah Budd, including $170,000 for past and future compensatory damages and $2 million in punitive damages. The court reduced the jury’s award to $300,000 based on the statutory caps under Title VII of the Civil Rights Act of 1964 which are applicable to compensatory and punitive damages. 

According to the EEOC, Budd’s coworkers and at least one manager made constant offensive and humiliating sexual comments to Budd. These comments included requests for Budd to perform demeaning sex acts and frequent remarks about rape and rape victims. Budd, herself a survivor of sexual assault, experienced physical illness and mental anguish as a result of her work environment. Budd reported the sexual harassment on several occasions to company officials, but SkyWest failed to remedy the situation, the EEOC said.

Such alleged conduct violates Title VII, which prohibits discrimination based on sex and retaliation for reporting a hostile work environment. The EEOC filed suit (Civil Action No. 3:22-cv-01807) in U.S. District Court for the Northern District of Texas, Dallas Division.

In granting the EEOC’s motion for injunctive relief, the court enjoined SkyWest from subjecting any parts or maintenance department employee at the Dallas-Fort Worth International Airport (DFW) to a hostile work environment based on sex in the future. It also ordered SkyWest to create and distribute a protocol for investigating complaints of harassment; conduct annual training for employees at DFW and those who are responsible for employee relations at DFW; post a notice in the DFW parts and maintenance department explaining the protections of Title VII; and notify the EEOC of any complaint of sexual harassment in that department at DFW. Additionally, the court denied SkyWest’s motion to set aside the jury’s verdict and for a new trial. In a separate order, the court awarded the EEOC $24,607 in costs. 

“The robust injunctive relief gained through this EEOC suit protects current and future employees from experiencing the hostile work environment Ms. Budd endured,” said Alexa Lang, a trial attorney in the EEOC’s Dallas District Office. “The EEOC will continue its fight for sexual harassment victims.”

The attorneys representing the EEOC include lead trial attorney Lang and trial attorneys Brooke López and Ann Henry. Budd was also personally represented by Edith Thomas of the law firm of Zipin, Amster & Greenberg.

For more information on sex-based discrimination, please visit https://www.eeoc.gov/sex-based-discrimination. For more information on sexual harassment, please visit https://www.eeoc.gov/sexual-harassment.

The EEOC’s Dallas District Office is responsible for processing charges of discrimination and conducting agency litigation for most of Texas and part of New Mexico.

The EEOC is the sole federal agency authorized to investigate and litigate against businesses and other private sector employers for violations of federal laws prohibiting employment discrimination. For public sector employers, the EEOC shares jurisdiction with the Department of Justice’s Civil Rights Division; the EEOC is responsible for investigating charges against state and local government employers before referring them to DOJ for potential litigation. The EEOC also is responsible for coordinating the federal government’s employment antidiscrimination effort. More information about the EEOC is available at www.eeoc.gov. Stay connected with the latest EEOC news by subscribing to our email updates.