A California judge has reduced a $6.5 million jury verdict to $1.3 million in the “reverse” religious discrimination case of a former employee of a temporary agency who claimed she was denied a promotion because of favoritism toward members of an obscure religious group.

U.S. District Judge Garland E. Burrell affirmed the $647,174 in compensatory damages awarded to Lynn Noyes in April. But he agreed with her former employer, Kelly Services, that the award of $5.9 million in punitive damages was unconstitutionally excessive.

A 1:1 ratio of punitive to compensatory damages “is the constitutional limit in this case,” Burrell said in a July 25 decision, finding that “while Kelly’s behavior was sufficiently reprehensible to warrant punitive damages, it was not highly egregious.”

The U.S. Supreme Court has of late disapproved of high punitive-to-compensatory ratios, ruling in State Farm v. Campbell, 538 U.S. 408 (2003), that “few awards exceeding a single-digit ratio between punitive and compensatory damages, to a significant degree, will satisfy due process.”

The jury's award of punitive damages to Noyes was more than nine times the compensatory award.

Noyes sued Kelly for giving the job of software development manager to a co-worker, Joep Jilesen, who belonged to the Fellowship of Friends, a “Fourth Way” -- or “esoteric Christianity” -- group influenced by the mystic Georgi Gurdjieff. Several other employees and the supervisor responsible for filling the position, William Heinz, were also members.

In his ruling, Burrell denied Kelly's motion for a new trial. "There was sufficient evidence to support [the jury's] finding that Heinz did not select Noyes for the position because she was not a member of the Fellowship,” he said.

On the issue of punitive damages, the judge found “substantial evidence ... that Heinz acted with oppression, malice or fraud.” He also said Kelly's argument that Jilesen wasn't really promoted to a management job “indicates Kelly was being deceitful by trying to hide the promotion.”

But Burrell cited State Farm in reducing the punitives to $647,174 –- the same amount as the compensatory damages, which included $500,000 for emotional distress and $147,174 for economic damages.

“Noyes was awarded significant compensatory damages,” he explained, and the portion for emotional distress “already contain[s] a punitive element.”

The Fellowship has about 2,000 members and says on its website that it practices “the art and science of awakening.” According to Noyes, 13 of the 35 full-time Kelly employees in Nevada City were members and, on the floor where she worked, nine of 13 employees belonged to the Fellowship.