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McCleary-Evans v. Maryland Department of Transportation
United States Court of Appeals for the Fourth Circuit
780 F.3d 582 (2015)
Dawnn McCleary-Evans (plaintiff) applied and was not hired for two positions in the State Highway Administration of the Maryland Department of Transportation (DOT) (defendant). McCleary-Evans brought suit under Title VII of the Civil Rights Act of 1964, claiming that she was not hired because she was an African American woman. McCleary-Evans claimed that the DOT employees in charge of hiring decisions had a bias in favor of white men and had predetermined that they would hire only white men for the positions. The complaint demonstrated that McCleary-Evans was qualified for the positions, but not that the ultimate hires were not qualified or were less qualified than she. The district court granted the DOT’s motion to dismiss. The district court held that because there was no direct evidence of discrimination, McCleary-Evans was required to plead a prima facie case of discrimination and failed to do so. The district court found that McCleary-Evans’s complaint did not plausibly support a claim of discrimination, as required under Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007). McCleary-Evans appealed, arguing that the district court applied the incorrect standard.
Rule of Law
Holding and Reasoning (Niemeyer, J.)
Dissent (Wynn, J.)
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