Friday, December 6, 2013

Davis v. Dallas Area Rapid Transit case brief

Davis v. Dallas Area Rapid Transit case brief summary
383 F.3d 309 (2004)


CASE SYNOPSIS
Plaintiff employees appealed from an order of the United States District Court for the Northern District of Texas, that granted summary judgment in favor of defendants, Dallas Area Rapid Transit (DART) and its chief of police, in a suit alleging race discrimination, retaliation, and hostile work environment under Title VII of the Civil Rights Act of 1964, 42 U.S.C.S. § 2000e et seq., and 42 U.S.C.S. §§ 1981(a), 1983, and 1988.

CASE FACTS
The complaint alleged that the failure to promote the employees was motivated by racial discrimination and was made in retaliation for their filing previous Equal Employment Opportunity Commission charges and because they publicly spoke out against race discrimination.

DISCUSSION

  • The district court held that the employees failed to raise a fact question on their claims regarding the failure to select them for promotions to lieutenant, and found their remaining claims were barred by res judicata, as they filed an earlier suit that had been dismissed in which the claims either were or could have been brought. 
  • They failed to show the lack of promotions were based on either race discrimination or retaliation. 
  • The claims that were precluded were closely connected in time and space with the claims dismissed in the prior suit. 
  • Even if plaintiffs established a prima facie case, they failed to raise a fact question about whether the defendants' proffered nondiscriminatory reason, their lack of qualifications, was pretextual.

CONCLUSION
The judgment of the district court was affirmed.

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