Legal News

Appeals Court Limits Use of Title VII against Individuals
Download PDF
1 Star2 Stars3 Stars4 Stars5 Stars (No Ratings Yet)
Loading...

On Wednesday, the 2nd U.S. Circuit Court of Appeals ruled that in a class-action lawsuit, plaintiffs cannot use statistical evidence of an institution’s pattern or practice of discrimination to establish the liability of individual defendants.

Addressing an issue of first impression the court said that in the case the inmates at a maximum security prison in New York had improperly attempted to demonstrate that an alleged systemic policy of discrimination proves that individual defendants were liable under Title VII of the Civil Rights Act.

The three-judge panel wrote, “Plaintiffs in this case offer no authority for the proposition that a statistics-based evidentiary framework used to determine the liability of an entity under Title VII is appropriate to establish the liability of individual state officials.”

  
What
Where


The suit had been initially dismissed by the U.S. District Judge David Larimer in Rochester, but the plaintiffs filed an appeal. According to records, the matter was a consolidated case begun in 1999 by two inmates against officials at the Elmira Correctional Facility. The prisoners Jerry Reynolds and Khalib Gould had accused officials of discriminating against them and other minorities by paying them less than other employed inmates.

The complaint, which was dismissed, had tried to impute intentional discrimination to the defendants by using a statistical framework showing a pattern of discrimination at the prison’s print shop. However the circuit said that the connection could not be established as “the pattern-or-practice framework is ill-suited to establish the liability of individual state officials named as defendants.”

The appeals court observed, “We have never employed the framework in such a manner, and we decline to do so here.” The attorney for the plaintiffs, Guy Talia, did not respond to requests for comments.

Get JD Journal in Your Mail

Subscribe to our FREE daily news alerts and get the latest updates on the most happening events in the legal, business, and celebrity world. You also get your daily dose of humor and entertainment!!




The cases are Jerry Reynolds v. Dave Barrett et al and Khalib Gould v. Terry Chamberlain et al, 2nd U.S. Circuit Court of Appeals, Nos. 10-4208 and 10-4235.





 

RELEVANT JOBS

Litigation Employment Attorney (Remote) in Burbank, CA.

USA-CA-Burbank

     We are a small and highly respected Burbank based REMOTE employment litigation d...

Apply now

Litigation Attorney

USA-CA-Torrance

​Position: Associate Attorney Firm: The Legacy Lawyers, P.C. Culture: "America First Pat...

Apply now

Litigation Attorney

USA-CA-Irvine

​Position: Associate Attorney Firm: The Legacy Lawyers, P.C. Culture: "America First Pat...

Apply now

Associate Attorney - Defense Litigation Experience

USA-TX-Dallas

Galloway\'s Dallas office is seeking an Associate Attorneys with 1 - 2 years of experience...

Apply now

BCG FEATURED JOB

Locations:

Keyword:



Search Now

Education Law Attorney

USA-CA-El Segundo

El Segundo office of a BCG Attorney Search Top Ranked Law Firm seeks an education law attorney with ...

Apply Now

Education Law Attorney

USA-CA-Carlsbad

Carlsbad office of a BCG Attorney Search Top Ranked Law Firm seeks an education law attorney with 4-...

Apply Now

Education Law and Public Entity Attorney

USA-CA-El Segundo

El Segundo office of a BCG Attorney Search Top Ranked Law Firm seeks an education law and public ent...

Apply Now

Most Popular

SEARCH IN ARCHIVE

To Top