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Parks v. City of Warner Robbins

43 F.3d 609 (1995)

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Parks v. City of Warner Robbins

United States Court of Appeals for the Eleventh Circuit

43 F.3d 609 (1995)

Facts

In 1985, the City of Warner Robbins (city) (defendant) enacted an antinepotism policy to decrease conflicts of interest, favoritism, family conflicts, and sexual harassment. The policy prohibited relatives from serving in supervisory positions within the same department. In 1989, Brenda Parks (plaintiff) and A. J. Mathern became engaged. Parks and Mathern were both in supervisory positions within the city’s police department. Parks and Mathern were informed that, because of the policy, Parks, who had less seniority, would be terminated following their marriage. Parks filed a lawsuit against the city, the mayor, and the city council (defendants). Parks argued that the policy was violative of (1) the Due Process Clause of the Fourteenth Amendment to the United States Constitution because it denied her the fundamental right to marry, (2) the right of intimate association rooted in the First Amendment because her employment was contingent on her decision not to marry, and (3) the Equal Protection Clause in the Fourteenth Amendment because the policy had a disparate impact on women due to the fact that more men held supervisory positions. The district court granted summary judgment for the city. Parks appealed.

Rule of Law

Issue

Holding and Reasoning (Birch, J.)

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