Mckenzie V. United States Tennis Association Incorporated, Et Al.
Case Background
On March 28, 2022, Kylie McKenzie filed a personal injury lawsuit alleging negligent hiring and failure to prevent sexual misconduct against the United States Tennis Association (USTA) for failing to protect her. The case was heard in the United States District Court, Florida Middle (Orlando). It was assigned to Judge Paul G. Byron and referred to Magistrate Judge Leslie Hoffman Price. [Case number: 6:22cv615]
Cause
Damages
As a direct result of the Defendant’s negligence, Plaintiff suffered sexual harassment and assault by Coach Aranda. This led to bodily injuries, significant pain, and suffering. Kylie also experienced disability, disfigurement, and mental anguish. She faced a reduced capacity to enjoy life, incurred expenses for hospitalization, medical, and nursing care, and lost earnings and the ability to earn money. Furthermore, the misconduct aggravated a pre-existing condition. These damages are either permanent or ongoing, and Plaintiff will continue to endure these losses in the future.
She sought judgment against Defendants for various forms of relief. She requested compensatory damages, prejudgment interest, and punitive damages. Additionally, she asked for attorneys’ fees and the costs associated with the action. Finally, Plaintiff sought any other relief the Court might consider fair and appropriate.
Key Arguments and Proceedings
Legal Representation
- Plaintiff(s): Kylie McKenzie
- Counsel for Plaintiff(s): Robert Allard | Amy Lynn Judkins | Maegen Peek Luka | Mark John Boskovich | Nicholas Donald Seidule | Edmund A. Normand
- Experts for Plaintiff(s): Dr. Steven Elig | Illiana Tintos
- Defendant(s): United States Tennis Association Incorporated | USTA Player Development Incorporated
- Counsel for Defendant(s): Kevin W. Shaughnessy | Erin Michelle Sales | Joyce Ackerbaum Cox | Meagan Leigh Martin | William Weber
- Experts for Defendant(s): Monica Applewhite, PhD.
Claims
Count I: Negligent Hiring, Supervision, Credentialing, and Retention
Defendants had a duty to carefully hire, supervise, and evaluate employees like Coach Aranda. They should have promptly investigated any concerns about coaches with tendencies toward inappropriate behavior with female athletes. Defendants were responsible for preventing Aranda from interacting privately with Plaintiff and other female athletes due to his history of misconduct. Despite this, they allowed him unrestricted access without adequate supervision. They failed to investigate prior allegations against Aranda before August 2018 and did not protect Plaintiff from harm by their employees.
Count II: Battery
Defendants, through their agents including Coach Aranda, committed battery by inappropriately touching Plaintiff without her consent. This conduct was intentional and offensive.
Count III: Intentional Infliction of Emotional Distress
Defendants and their agents, including Coach Aranda, intentionally inflicted severe emotional distress on Plaintiff through sexual assault and battery. This outrageous conduct caused significant mental suffering.
Count IV: Negligence
Defendants breached their duty of care in several ways: a. Failing to protect Plaintiff from harassment and assault. b. Employing unsuitable coaches. c. Not enforcing policies to prevent inappropriate behavior. d. Neglecting to investigate complaints about misconduct. e. Failing to inform athletes about coaches with misconduct histories. f. Inadequately disciplining coaches, including Coach Aranda. g. Not informing Plaintiff about Aranda’s past behavior. h. Failing to detect inappropriate behavior towards Plaintiff. i. Not controlling or intervening in coaches’ actions. j. Lacking policies to protect female athletes. k. Failing to prevent escalation of inappropriate conduct. l. Lacking criteria for coaching assignments. m. Not ensuring coach accountability. n. Ignoring detrimental behavior. o. Not ensuring compliance with rules and laws. p. Failing to detect unprofessional behavior. q. Negligent in appointing coaches. r. Allowing unsupervised coaching.
Count V: Respondeat Superior
Defendants were liable for Coach Aranda’s actions as he acted within his employment scope. Aranda used his position to assault and batter athletes, including Plaintiff, at USTA facilities.
Count VI: Punitive Damages
Defendants were liable for punitive damages due to Aranda’s intentional sexual misconduct and gross negligence, which contributed to Plaintiff’s damages.
Defense
Defendants denied all allegations, asserting that Aranda was not acting within the scope of his employment when he allegedly committed the sexual misconduct described in the Complaint. Consequently, Defendants argued that they could not be held liable for his intentional torts. They maintained that they had not breached any duty to Plaintiff.
Expert Testimony
Dr. Steven Elig
Dr. Steven Elig testified for the Plaintiff, offering insights on causation and damages. His testimony covered psychiatric diagnoses, prognosis, and the extent of impairment and symptoms. He provided expert opinions based on medical probability and certainty.
Illiana Tintos
Illiana Tintos, a non-retained expert, also testified for the Plaintiff. She focused on the nature and extent of the Plaintiff’s psychological harms and identified the approximate causes of these harms.
Dr. Monica Applewhite
Dr. Monica Applewhite presented testimony for the Defendants based on her expert report. She discussed the standards of care required for protecting adult athletes by a National Governing Body. Additionally, she addressed the standards for preventing and responding to sexual misconduct and harassment in the workplace. Her testimony evaluated the Defendants’ responses to incidents of sexual misconduct, their policies, and her opinions on these matters.
Jury Verdict
On May 06, 2024, the Florida jury determined in the first phase of the verdict that USTA had failed to protect Kylie from sexual misconduct and that their negligence had harmed her. Accordingly, they awarded her $3 million as special damages. In Phase 2 of the verdict, the jury determined that USTA engaged in conduct that warrants punitive damages and awarded Kylie $6 million. Thus, a total of $9 million was awarded against USTA in this sexual misconduct lawsuit.
On May 07, 2024, Judge Paul G. Byron entered a judgment consistent with the verdict.
Post-trial Motions
On June 04, 2024, Defendants filed a Renewed Motion for Judgment as a Matter of Law under Rule 50(b), arguing that the trial evidence did not provide a legally sufficient basis for the jury’s verdict in favor of Plaintiff. Alternatively, they sought a new trial under Rule 59(a), claiming the award was unsupported by the evidence and that errors in evidentiary rulings and jury instructions had prejudiced them. They also requested remittitur of the punitive damages award under Rule 59(e).
Court Documents:
Available upon request
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