White and Hispanic candidates for promotion in the New Haven, CT fire department sued various city officials in the United States District Court for the District of Connecticut when the New Haven Civil Service Board (CSB) failed to certify two exams needed for the plaintiffs’ promotion to Lieutenant and Captain. The CSB did not certify because the results of the test would have promoted a disproportionate number of white candidates in comparison to minority candidates. The plaintiffs argued that their rights under Title VII of the Civil Rights Act of 1964, 42 U.S.C. Section 2000e, and the 14th Amendment Equal Protection Clause were violated. The federal district court granted the defendants’ motion for summary judgment. On appeal, the United States Court of Appeals for the Second Circuit affirmed. It reasoned that the CSB, by refusing to certify the results of the promotional exam, was trying to fulfill its obligations under the rules utilized by the plaintiffs in their argument and therefore was protected in its actions.
Title VII of the Civil Rights Act of 1964, 42 U.S.C.S. § 2000e et seq. , prohibits employment discrimination on the basis of race, color, religion, sex, or national origin. Title VII prohibits both intentional discrimination (known as disparate treatment) as well as, in some cases, practices that are not intended to discriminate but in fact have a disproportionately adverse effect on minorities (known as disparate impact).
Brief Fact Summary:
After the city of New Haven, Connecticut (Defendant) and its officials (Defendants) refused to certify the results of a firefighter promotion exam because of the practices disparate impact on minorities, the white and Hispanic firefighters who passed the exam (Plaintiffs) brought suit alleging racial discrimination in violation of Title VII of the Civil Rights Act of 1964.