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Keywords

plaintiffdamagesappealtrialverdictmotiondiscriminationjury trialadmissibilityequitable relief
plaintiffappealmotiondiscriminationappellee

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Chin v. Port Authority of New York & New Jersey, 685 F.3d 135, 115 Fair Empl.Prac.Cas. (BNA) 720, 95 Empl. Prac. Dec. P 44,555

Facts

The plaintiffs, members of the Port Authority Police Asian Jade Society, alleged that they were denied promotions to Sergeant due to their race. They filed a charge with the EEOC in 2001, which found reasonable cause for discrimination. A jury trial resulted in a unanimous verdict that the Port Authority discriminated against seven plaintiffs, awarding them back pay and equitable relief. The Port Authority appealed, challenging the admissibility of evidence and the jury's verdict.

The eleven plaintiffs-appellees in this case are Asian Americans who were employed by that department as police officers.

Issue

The main legal issues included whether the pattern-or-practice method of proof was available to nonclass, private plaintiffs in a Title VII claim, and whether the evidence supported the jury's findings of discrimination.

The Court of Appeals, Livingston, Circuit Judge, held that: 1 the pattern-or-practice method of proof was not available to nonclass, private plaintiffs bringing a Title VII claim;

Rule

The Court held that the pattern-or-practice method of proof is not available to nonclass, private plaintiffs bringing a Title VII claim, but that statistical evidence can support a disparate impact claim.

The Court of Appeals, Livingston, Circuit Judge, held that: 2 statistical evidence presented by plaintiffs' expert was sufficient to prove plaintiffs' disparate impact claim;

Analysis

The court analyzed the evidence presented, noting that while the pattern-or-practice method was not applicable, the statistical evidence demonstrated a significant disparity in promotions between Asian Americans and white officers. The jury was instructed on three theories of discrimination, and the court found sufficient evidence to support the jury's verdict regarding individual disparate treatment and disparate impact.

The court analyzed the evidence presented, noting that while the pattern-or-practice method was not applicable, the statistical evidence demonstrated a significant disparity in promotions between Asian Americans and white officers.

Conclusion

The Court of Appeals affirmed the jury's finding of discrimination against seven plaintiffs but vacated the damages awarded to four plaintiffs whose claims were time-barred, remanding for a new trial on damages.

Affirmed in part, vacated in part, and remanded.

Who won?

The prevailing party was the seven plaintiffs who proved their claims of discrimination, as the jury found sufficient evidence of intentional discrimination and disparate impact.

The prevailing party was the seven plaintiffs who proved their claims of discrimination, as the jury found sufficient evidence of intentional discrimination and disparate impact.

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