In what the EEOC has called “one of its finest moments” in its effort to “combat employment discrimination,” a jury awarded $240 million to 32 individuals in an ADA case brought by the EEOC. It was the EEOC’s largest jury verdict ever. The award for compensatory and punitive damages amounted to $7.5 million per individual. Because of the caps on emotional distress and punitive damages, the award has been reduced to $1.6 million, which is $50,000 for each individual.

The circumstances leading to the verdict are quite unique. The EEOC represented 32 intellectually disabled workers who were paid just $65.00 a month to eviscerate turkeys on a full-time basis at Hill Country Farms. The workers lived in company-provided bunkhouses, which had been shut down by the state due to substandard construction, hazards and other unsafe living conditions, such as a leaky roof and insect infestation. The disabled workers alleged that non-disabled supervisors abused them verbally and physically. The EEOC’s ADA claims included disparate treatment and harassment based on the employees’ disabilities.

While the facility had already been shut down, and it is unlikely that there are many other employers who provide similar working conditions, the case gives the EEOC a burst of adrenaline. At a time when private class actions face a number of legal hurdles due to recent Supreme Court decisions, this victory bolsters the EEOC’s strategy to focus on systemic discrimination, even in harassment cases. The EEOC does not need to satisfy the same Rule 23 requirements that have hampered private plaintiffs attempting to bring class claims.

The case also rewards the EEOC for its reluctance to negotiate less than full economic relief during the conciliation process. The $240 million verdict was for compensatory and punitive damages. Backpay for the individuals was already awarded in the EEOC’s favor at the summary judgment stage.