Peeples v. City of Detroit

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Plaintiffs, 11 minority firefighters who were laid off by Detroit in 2012 as part of a reduction in force (RIF) that followed the city’s bankruptcy, sued the city and their union, (DFFA), alleging a violation of Title VII of the 1964 Civil Rights Act, 42 U.S.C. 2000e. The district court rejected their claims on summary judgment, finding that only one Plaintiff had exhausted his administrative remedies to pursue a claim against the city, but that even on the merits, Plaintiffs failed to present direct evidence or to establish a prima facie case under the circumstantial evidence approach, which includes a heightened burden in a RIF. The court concluded that Plaintiffs could not establish that the DFFA breached its duty of fair representation. The Sixth Circuit agreed that 10 Plaintiffs failed to exhaust administrative remedies, that there was no direct evidence of discriminatory motive, and that Plaintiffs’ statistical evidence was not probative and did not establish a circumstantial case. The court reversed as to DFFA, holding that a prima facie disability discrimination claim against a union does not require that a plaintiff demonstrate that the union breached its duty of fair representation. View "Peeples v. City of Detroit" on Justia Law