Front Pay and Future Earnings in Title VII Cases

An employee brought a successful action against her former employer for violating Title VII. The Seventh Circuit, affirming the district court's award of both front pay and lost future earnings, held that "front pay may be awarded under Title VII in cases where reinstatement is unavailable." The Seventh Circuit also cautioned lower courts to distinguish between front pay, the equitable remedy which gives the plaintiff the same benefit he/she would have received had he/she been reinstated, and lost future earnings, which compensates the plaintiff for reputational harms that result in diminished future earnings.