- 5 - discrimination claim under Title VII of the Civil Rights Act of 1964 against their employer. The parties eventually reached a settlement in which the employees would receive varying amounts based on length of service and rate of pay. The employer withheld Federal income taxes on the amounts received by the taxpayers. Id. at 230-231. The taxpayers sought refunds of the withheld taxes on the ground that the settlement amounts were excludable under section 104(a)(2) as "damages received * * * on account of personal injuries or sickness." Id. at 232. The Supreme Court held that the nature of the claim underlying the taxpayers' settlement awards controlled the excludability of the settlements under section 104(a)(2). Id. at 237. The Court noted that Title VII under the 1964 Civil Rights Act limited "available remedies to backpay, injunctions, and other equitable relief." Id. at 238. The Court further stated that The remedy, correspondingly, consists of restoring victims, through backpay awards and injunctive relief, to the wage and employment positions they would have occupied absent the unlawful discrimination. * * * Nothing in this remedial scheme purports to recompense a Title VII plaintiff for any of the other traditional harms associated with personal injury, such as pain and suffering, emotional distress, harm to reputation, or other consequential damages * * * Id. at 239. Since the taxpayers could receive under Title VII only wages, which they otherwise would have paid taxes upon in the normal course, the Court held that Title VII did not redress "a tort-like personal injury within the meaning of sectionPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011