Adams v. City of Chicago

A group of black and Hispanic law enforcement officers (plaintiffs) employed by the City of Chicago (the City) (defendant) alleged the City’s methods for promoting officers created disparate-impact discrimination against minorities in violation of Title VII of the Civil Rights Act of 1964 (Title VII), 42 U.S.C. § 2000e et seq. The City used a written examination, created by an outside consultant in 1994, to make officer-to-sergeant promotion decisions in August 1994, March 1996, and February 1997. In January 1997, a city-appointed task force recommended that in the future, 30 percent of officer-to-sergeant promotions be based on merit, meaning officers’ job performance as evaluated by their supervisors. The City did not follow this recommendation in making the February 1997 officer-to-sergeant promotions. Beginning in 1989, the City considered merit in filling 20 percent of its detective positions. Beginning in 1998, the City made 30 percent of its officer-to-sergeant and sergeant-to-lieutenant promotions merit based. The plaintiffs argued that because the City had considered merit in filling detective positions since 1989, and because the 1997 task force had recommended future merit-based officer-to-sergeant promotions, the City could have used merit in making 30 percent of its 1997 officer-to-sergeant promotions. [The district court granted summary judgment for the City.] The plaintiffs appealed.