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Littlejohn v. City of New York

United States Court of Appeals for the Second Circuit
795 F.3d 297 (2015)


Facts

Dawn Littlejohn (plaintiff), an African American woman, worked in a management position for the New York City Administration for Children’s Service (ACS) (defendant). ACS merged with the Department of Juvenile Justice. During that process, Littlejohn complained to her supervisors about discriminatory practices in determining which employees would be retained and named to various positions. Subsequently, Littlejohn was demoted to a non-management position with less pay. Littlejohn’s replacement was white and, according to Littlejohn, less qualified for the position. Littlejohn brought suit against ACS, her supervisors, and the City of New York (defendants) in the United States District Court for the Southern District of New York, alleging disparate treatment based on her race and retaliation for her complaints about discrimination. The district court granted the city’s motion to dismiss under Federal Rule of Civil Procedure 12(b)(6). Littlejohn appealed.

Rule of Law

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Issue

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Holding and Reasoning (Droney, 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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