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Keywords

lawsuitplaintiffpleamotiondiscrimination
plaintiffattorneypleadiscrimination

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Brown v. Coach Stores, Inc., 163 F.3d 706, 78 Fair Empl.Prac.Cas. (BNA) 917, 74 Empl. Prac. Dec. P 45,682

Facts

Marva Brown, an African-American employee at Coach Stores, Inc., worked as a receptionist and claimed she was denied promotions due to her race. Despite making repeated requests for promotions during annual reviews, she alleged that Coach promoted predominantly non-minority employees. Brown filed a charge with the EEOC and later a lawsuit, asserting claims under Title VII. The district court dismissed her complaint, stating she failed to specify positions for which she applied and was rejected.

Marva Brown, an African-American who has worked as a receptionist in Coach's Human Resource Department at its headquarters in Manhattan since 1988. In December 1996, Brown, through her attorney, filed a Notice of Charge of Discrimination with the Equal Employment Opportunity Commission (EEOC). In this charge, she claimed that despite repeated requests to be promoted, Coach had refused to promote her and had instead promoted dozens of non-minority employees and 'scarcely any' minorities.

Issue

Did Marva Brown adequately plead her claims of race discrimination under Title VII, specifically regarding failure to promote, pattern and practice discrimination, disparate impact, and hostile work environment?

Did Marva Brown adequately plead her claims of race discrimination under Title VII, specifically regarding failure to promote, pattern and practice discrimination, disparate impact, and hostile work environment?

Rule

To establish a prima facie case of discrimination under Title VII, a plaintiff must show that they are a member of a protected class, applied and were qualified for a job for which the employer was seeking applicants, were rejected for the position, and that the position remained open. The pleading requirements are lenient, but a specific application for a position is generally required.

To establish a prima facie case of discrimination under Title VII, a plaintiff must show that she is a member of a protected class; she applied and was qualified for a job for which the employer was seeking applicants; she was rejected for the position; and the position remained open and the employer continued to seek applicants having the plaintiff's qualifications. McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802, 93 S.Ct. 1817, 36 L.Ed.2d 668 (1973).

Analysis

The court found that Brown's failure to allege that she applied for specific positions was fatal to her claims. Although she argued that infrequent job postings and a pattern of discrimination discouraged her from applying, the court held that she did not meet the basic pleading requirements. The court also noted that her disparate impact claim lacked a causal connection between Coach's policies and the alleged underrepresentation of minorities.

We find, therefore, no reason to relieve Brown of meeting the de minimis pleading requirement in a Title VII race discrimination case of delineating a position or positions to which she applied and was rejected. Even assuming that employee adequately pleaded a claim of pattern and practice discrimination by employer, she was not relieved of her burden, required for prima facie Title VII failure-to-promote claim, of showing that she applied for a specific position, where she failed to allege the specific positions to which she would have applied had the alleged discriminatory practices not existed.

Conclusion

The court affirmed the district court's dismissal of Brown's complaint for failure to state a claim under Title VII.

We hereby AFFIRM the decision of the district court dismissing Brown's complaint for failure to state a claim.

Who won?

Coach Stores, Inc. prevailed in this case as the court upheld the dismissal of Brown's claims. The court reasoned that Brown's failure to specify positions for which she applied and was rejected was a critical deficiency in her complaint. The court emphasized the importance of meeting the pleading requirements to ensure that claims of discrimination are adequately substantiated.

Coach Stores, Inc. prevailed in this case as the court upheld the dismissal of Brown's claims. The court reasoned that Brown's failure to specify positions for which she applied and was rejected was a critical deficiency in her complaint.

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