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Baylie v. Federal Reserve Bank of Chicago

United States Court of Appeals for the Seventh Circuit
476 F.3d 522 (7th Cir. 2007)


Facts

A class of employees sued the Federal Reserve Bank of Chicago (the Bank) (defendant) for race, sex, and age discrimination under Title VII of the Civil Rights Act of 1964 (Title VII), 42 U.S.C. § 2000e et seq. A district court de-certified the class but permitted the employees to pursue individual claims. Two remaining employees’ (plaintiffs) claims remained for resolution. The plaintiffs relied on an expert report, compiled during the class action proceedings, concluding that the Bank was less likely to promote black employees than white employees. In making this finding, the expert looked at all non-managerial workers at the Bank during a five-year period. The expert found that overall, workers had a 0.25 probability of being promoted. A regression analysis showed that white employees had a 0.27 probability of being promoted, and black employees had a 0.20 probability of being promoted. This supported a conclusion that the average white worker received an extra promotion once every twentieth year, as compared with the average black worker. The plaintiffs maintained this report was sufficient to make a prima facie showing of individual disparate impact. The district court rejected the plaintiffs’ argument and granted summary judgment for the Bank. The plaintiffs appealed.

Rule of Law

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Issue

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Holding and Reasoning (Easterbrook, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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