Littlefield v. McGuffey

Facts

On September 14, 1988, Susanne Littlefield, Plaintiff, a twenty-threeyear old, inserted an application to rent an apartment from Malcolm McGuffey, Defendant, who went by multiple aliases. The parties agreed that Littlefield, Sandra, Littlefield’s sister, and Littlefield’s two-year-old daughter, Shaunte, would occupy the apartment. The parties alsostipulated that Defendant would replace the carpet in exchange of Littlefield paying the cost of the installation.From that moment till September 27, Littlefield, her family, and friends painted the apartment and moved some possessions into it. On September 27, Bruce Collins, Shaunte’s father, went with Shaunte to see Defendant to pay for the carpet installation. Collins was not the same race as Littlefield. When Defendant met Collins, Defendant began to become agitated and told Collins that the apartment wasbeing rented to someone else. Defendant then called Littlefield to her work phone number and told her that the apartment was being rented to someone else, the locks had already been changed, and that Littlefield’s possession were removed. Littlefield began to become scared, upset, physically ill, and embarrassed. Littlefield began to cried and left work early. Subsequently, Defendant made numerous harassing phone calls to Littlefield and her sister where he was frequently pretended to be another person. Also, the phone calls were filled with racist epithets and other insults. Moreover, Defendant even left a note on Littlefield’s new residence door where he threatened to kill Collins and used racist slurs. Again, these incidents continued to make Littlefield extremely scared for herself and her daughter. Littlefield brought suit against Defendant for violations of the Equal Opportunity in Housing provision of the Civil Rights Act of 1866, the Fair Housing Act, and intentional infliction of emotional distress under Illinois law. At trial, Defendant contended that he refused to rent to Littlefield because she had a poor credit and rental history, not due to a racial reason. Nevertheless, Defendant did not provided evidence to support those claims. On the contrary, Littlefield provided evidence that she had adequate credit, Defendant did not obtain it, and that she was a good tenant in the past. The jury found in Littlefield’s favor and awarded her $50,000 in compensatory and $100,000 in punitive damages. Additionally, the trial court awarded Littlefield attorney’s fees of $140,000. Defendant appealed.