Fair Housing Act and Sexual Harassment

Not a 1983 case, but interesting nonetheless.  Quigley v. Winter (CA8) (here):

[PUBLISHED] [Riley, Author, with Hansen and Gruender, Circuit Judges] Civil case - civil rights. A claim for hostile housing environment created by sexual harassment is actionable by the tenant under the Fair Housing Act; there was sufficient evidence to support the jury's verdict that defendant subjected plaintiff to unwelcome sexual harassment and that the harassment was so pervasive or severe as to interfere with or deprive her of her right to use or enjoy her home; jury verdict for plaintiff on her quid pro quo sexual harassment claim affirmed; evidence was sufficient to support jury's verdict that plaintiff was subjected to coercion, intimidation and interference with her housing rights; instructions on discriminatory housing practices claim were not erroneous; challenges to evidentiary rulings rejected; district court did not err in submitting punitive damages issue to the jury as defendant admitted he knew sexual harassment was unlawful, that he was an experienced landlord and that he knew the lease agreement forbade discrimination based on sex; $250,000 punitive damage was excessive, but the district court erred in reducing it to $20,527; the court finds an appropriate award is $54,750, which is four times the compensatory damage award; attorneys' fees award reduced to $78,044. Judge Gruender, concurring in part and dissenting in part.