Jackson v. University of New Haven

James Jackson (plaintiff) was an experienced minor-league professional football coach who had never coached college football. When the University of New Haven (UNH) (defendant) lost its head football coach to a job in the National Football League, Jackson applied for the vacant head-coaching position. When the job was posted, UNH specifically indicated that college-coaching experience was required. UNH received 36 applications, and a search committee then chose six applicants to interview, eventually hiring Darren Rizzi, a former UNH assistant coach. Jackson was African American, whereas all six finalists for the job were White (and had college-coaching experience). Jackson filed a civil-rights suit against UNH, alleging racial discrimination in the hiring process in violation of 42 U.S.C. § 1981. Jackson made claims on disparate-treatment and disparate-impact theories. The disparate-treatment theory posited that the discrimination was intentional, whereas the disparate-impact theory argued that a facially neutral requirement (prior college coaching experience) still had a discriminatory impact. UNH filed a motion to dismiss the suit, arguing that Jackson did not meet the qualifications for employment and failed to make a prima facie case of disparate impact from the prior college-coaching-experience qualification. To prevail on a disparate-treatment claim, Jackson must show that he (1) is a member of a protected class, (2) was qualified for the employment, (3) had an adverse employment decision, and (4) had circumstances giving rise to an inference of discrimination. Although points 1 and 3 were conceded, point 2 was deeply argued. Jackson maintained that his minor-league coaching experience should have qualified him, whereas UNH maintained that a college coach who could ensure National Collegiate Athletic Association compliance was necessary. On a disparate-impact basis, Jackson argued the lack of African-American coaches in college football and at UNH, which UNH argued did not make a prima facie case. UNH filed a motion to dismiss the suit for failure to state a claim.