Delaware Jury Awards $1.5 Million to KFC Supervisor Penalized for Breastfeeding

Autumn Lampkins was hired as an assistant manager trainee at a Dover-area KFC franchise owned by Mitra QSR in December 2014, while she was nursing a four-month-old child. From the start, pumping at work was a source of conflict. She was initially directed to use a single-stall bathroom, then moved to a manager's office that had a window facing the restaurant floor and an active surveillance camera. Coworkers repeatedly interrupted her pumping breaks and complained about the time she was taking away from the floor.

The pressure did not stop there. Lampkins was demoted from her assistant manager position, had her pay reduced, and was transferred to a second Mitra QSR location where her opportunities to pump were even more limited. She alleged the cumulative effect was that her milk dried up entirely, ending her ability to breastfeed her child. She brought suit against both Mitra QSR, LLC and Mitra QSR KNE, LLC in the U.S. District Court for the District of Delaware, asserting sex discrimination and hostile work environment claims under Title VII.

Patrick C. Gallagher and Raeann Warner of Jacobs and Crumplar, P.A. represented Lampkins at trial. The jury found that Mitra unlawfully discriminated against Lampkins by demoting her and reducing her hours because she was lactating, and that the company subjected her to a hostile work environment tied to the same conduct. In February 2019, the jury awarded $25,000 in compensatory damages and $1,500,000 in punitive damages, for a total of $1.525 million.

The verdict drew national attention as one of the larger jury awards in a lactation-discrimination case. Federal law caps punitive damages in Title VII employment cases at $300,000 per defendant, meaning the punitive portion faced potential reduction even before any post-trial motion.

On June 4, 2019, Judge Colm F. Connolly granted the defense's post-trial motion in part. He vacated the jury's hostile work environment findings, concluding those conclusions were not supported by the evidence, and entered judgment for Mitra on those claims. He ordered a new trial on the remaining sex discrimination claims tied to the demotion and the reduction in Lampkins' work hours.