Luceus v. State

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The First Circuit affirmed the district court's grant of summary judgment to Defendants, the Rhode Island Department of Labor and Training and the State, on Plaintiff's complaint alleging discrimination in violation of Title VII of the Civil Rights Act, 42 U.S.C. 2000e-2, holding that summary judgment was properly granted. In his complaint, Plaintiff claimed that the Department's promotion practices had a disparate impact on minority employees and that the Department declined to promote her because she is black. The district court granted summary judgment in favor of Defendants. The First Circuit affirmed, holding (1) because Plaintiff could not show a disparate impact in the absence of statistical and statistically significant evidence, the district court correctly granted summary judgment to Defendants on Plaintiff's claim of disparate impact; and (2) Plaintiff failed to present enough evidence for a reasonable jury to conclude that Defendants' stated reason for failing to promote her was pretextual. View "Luceus v. State" on Justia Law