Moran v. Selig
United States Court of Appeals for the Ninth Circuit
447 F.3d 748 (2006)
- Written by Steven Pacht, JD
Facts
Mike Colbern (plaintiff) played Major League Baseball (MLB) in 1978 and 1979. He was not entitled to pension or medical benefits from MLB (MLB benefits) because players of his era had to play in the major leagues for at least four or five years to qualify. The so-called Negro Leagues were associations of professional baseball clubs with exclusively Black players that arose because MLB excluded Black players until 1947. In the 1990s, in an effort to atone for its past discrimination, MLB adopted benefit plans for pre-1948 veterans of the Negro Leagues (NL plans). The NL plans provided benefits to players (all of whom were Black) based on their service in the Negro Leagues, whether or not they played in the major leagues, or, if they did, whether or not they accrued enough service time to earn MLB benefits. Colbern, who was White, brought a class action against MLB’s commissioner Alan “Bud” Selig and MLB’s teams (defendants), alleging that Selig and the teams violated Title VII of the Civil Rights Act of 1964. Specifically, Colbern alleged that Selig and the teams engaged in race-based employment discrimination by denying him MLB benefits due to his lack of MLB service time even though Black players from the same era with comparable MLB service time received benefits under the NL plans if they also played in the Negro Leagues. The district court granted summary judgment to Selig and the teams. Colbern appealed. Selig and the MLB teams responded that (1) Colbern did not suffer an adverse employment action because the NL plans were not based on an employment relationship with MLB; (2) Colbern was not similarly situated in all material respects with the Black players who received NL-plans benefits because he had not been excluded from MLB due to his race and thus was not prevented for nonbaseball reasons from acquiring sufficient service time to earn MLB benefits; and (3) remedying discrimination against specifically identifiable players was a legitimate, nondiscriminatory, and nonpretextual reason for compensating the victims.
Rule of Law
Issue
Holding and Reasoning (Reinhardt, J.)
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