Harriston v. Chicago Tribune Co.
United States Court of Appeals for the Seventh Circuit
992 F.2d 697 (1993)

- Written by Mary Phelan D'Isa, JD
Facts
Octavia Harriston (plaintiff), a Black woman and former manager at the Chicago Tribune Company (Tribune) (defendant), sought class certification for all Black people who had been excluded from management positions at the Tribune. Harriston, who had been promoted to a manager position and transferred back and forth from the advertising and employment-relations departments at the Tribune, alleged age and race discrimination after she received a satisfactory rating and was criticized for her sales level. The district court refused to certify the class because Harriston failed to show that she was a member of the class she purported to represent: all Black employees whom the Tribune did not promote to management positions. Harriston had been promoted to a manager position in the employee-relations department, and Harriston failed to cite a specific manager position that the Tribune denied her. Harriston appealed.
Rule of Law
Issue
Holding and Reasoning (Manion, J.)
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