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Between 2002 and 2005, Otto May, Jr., a pipefitter at a Chrysler plant in Illinois, was the target of more than fifty racist, homophobic, and anti-Semitic messages and graffiti. He received death threats, his bike and car tires were punctured, and someone poured sugar into the gas tank of his car. In one incident, a dead bird wrapped in toilet paper to look like a member of the Ku Klux Klan was placed at his workstation. May complained to Chrysler. The employer documented the complaints and began an investigation. Records were checked to determine who was in the building when the incidents occurred, and the graffiti handwriting was examined. The company reminded its workers that employee harassment was not acceptable. The harassers were never caught, but the incidents became fewer and eventually stopped. May filed a suit against Chrysler in a federal district court for hostile-environment harassment. A jury awarded May $709,000 in compensatory damages and $3.5 million in punitive damages. When the judge overturned the punitive damages award, May appealed.
Were the steps Chrysler took to stop and prevent the harassment against its employee sufficient to protect the company from an assessment of punitive damages?
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