44 Fair empl.prac.cas. 509, 41 Empl. Prac. Dec. P 36,453 Johnnie Gilbert, Horace Walters, Andrew Lockhart and Billy O'DOnalD v. City of Little Rock, Arkansas the Civil Service Commission of the City of Little Rock, Arkansas Walter E. "Sonny" Simpson, Individually and in His Official Capacity as Chief of Police of the City of Little Rock, Arkansas and Carlton E. McMullin Individually and in His Official Capacity as City Manager of the City of Little Rock, Arkansas

799 F.2d 1210
CourtCourt of Appeals for the Eighth Circuit
DecidedOctober 30, 1986
Docket85-1823
StatusPublished
Cited by2 cases

This text of 799 F.2d 1210 (44 Fair empl.prac.cas. 509, 41 Empl. Prac. Dec. P 36,453 Johnnie Gilbert, Horace Walters, Andrew Lockhart and Billy O'DOnalD v. City of Little Rock, Arkansas the Civil Service Commission of the City of Little Rock, Arkansas Walter E. "Sonny" Simpson, Individually and in His Official Capacity as Chief of Police of the City of Little Rock, Arkansas and Carlton E. McMullin Individually and in His Official Capacity as City Manager of the City of Little Rock, Arkansas) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eighth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
44 Fair empl.prac.cas. 509, 41 Empl. Prac. Dec. P 36,453 Johnnie Gilbert, Horace Walters, Andrew Lockhart and Billy O'DOnalD v. City of Little Rock, Arkansas the Civil Service Commission of the City of Little Rock, Arkansas Walter E. "Sonny" Simpson, Individually and in His Official Capacity as Chief of Police of the City of Little Rock, Arkansas and Carlton E. McMullin Individually and in His Official Capacity as City Manager of the City of Little Rock, Arkansas, 799 F.2d 1210 (8th Cir. 1986).

Opinion

799 F.2d 1210

44 Fair Empl.Prac.Cas. 509,
41 Empl. Prac. Dec. P 36,453
Johnnie GILBERT, Horace Walters, Andrew Lockhart and Billy
O'Donald, Appellants,
v.
CITY OF LITTLE ROCK, ARKANSAS; the Civil Service Commission
of the City of Little Rock, Arkansas; Walter E. "Sonny"
Simpson, Individually and in his official capacity as Chief
of Police of the City of Little Rock, Arkansas; and Carlton
E. McMullin, Individually and in his official capacity as
City Manager of the City of Little Rock, Arkansas, Appellees.

No. 85-1823.

United States Court of Appeals,
Eighth Circuit.

Submitted March 14, 1986.
Decided Aug. 28, 1986.
Rehearing and Rehearing En Banc Denied Oct. 30, 1986.

Phillip J. Duncan, Little Rock, Ark., for appellants.

Philip K. Lyon, Little Rock, Ark., for appellees.

Before HEANEY, Circuit Judge, FLOYD R. GIBSON, Senior Circuit Judge, and FAGG, Circuit Judge.

HEANEY, Circuit Judge.

Eleven black police officers appeal from a district court judgment dismissing their Title VII complaint alleging racially discriminatory promotion policies. We reverse.

I. BACKGROUND

On September 27, 1978, Johnnie Gilbert, Horace Walters, Andrew Lockhart, and Billy O'Donald filed a complaint in district court against the City of Little Rock, the Civil Service Commission (CSC),1 and Walter E. "Sonny" Simpson, alleging racial discrimination by the Little Rock Police Department (LRPD), in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. Sec. 2000e-5(f).2 On February 22, 1979, Julius Bryant, Jack Matlock, Maxie Alexander, Grady Anthony, Marcella Wilson, Finis Lowe,3 Jessie Briscoe, and Larry Brazzelle filed a motion to intervene and a complaint. Plaintiffs and intervenors (appellants) charged LRPD with racial harassment and with discriminatory disciplinary and promotion policies, and sought injunctive relief and compensatory and punitive damages. The district court found that there was neither intentional discrimination nor disparate impact against appellants and dismissed their complaints. Gilbert v. City of Little Rock, 544 F.Supp. 1231, 1261 (E.D.Ark.1982) (Gilbert I ). On appeal, this Court affirmed the district court on the harassment and discipline issues and remanded on the promotion issue. Gilbert v. City of Little Rock, 722 F.2d 1390 (8th Cir.1983) (Gilbert II ). On remand, the district court once again dismissed the promotion complaint. Gilbert v. City of Little Rock, No. LR-78-340 (E.D.Ark. filed June 7, 1985) (Gilbert III ). This appeal followed.

II. DISCUSSION

Because this is the second time the promotion issue has come before this Court, this discussion will draw heavily from our first opinion.

In Gilbert I, the district court found that although the appellants had made a prima facie showing that LRPD's promotional process had a disparate impact on the black officers, LRPD successfully rebutted the accuracy and significance of appellants' statistical evidence. The district court compared the average composite, oral, and service scores and concluded that none of the subparts of the promotional process had an adverse impact on appellants.

In Gilbert II, this Court disagreed with the district court's analysis:

Data presented at trial regarding the testing procedures for promotion to sergeant reveals that * * * the passing rate for the black candidates taking the written examination was comparable to that of the white candidates. * * * It was primarily based on these statistics that the district court concluded the testing procedure did not have a disparate impact on black officers seeking promotion.

The critical factor in being promoted, however, was not to be placed on the list, but to be placed at a high standing on the list. This is especially critical in view of the fact that the certified lists automatically expired at the end of one year. * * *

By failing to focus on the ranking aspect of the promotional system, the district court neglected to adequately consider the interrelationship of the component factors and, more specifically, whether the oral interview and performance appraisal factors, which accounted for between 40%-50% of a candidate's composite score, had a disparate impact on black officers' scores, and thus on their rank on the list. It is not sufficient for such a determination to compare the average scores of whites and blacks on these subparts of the procedure. Rather, the correlation between scores on the written exam on the one hand and on the oral exam, performance appraisal, and chief's rating on the other needs to be examined. Thus, if there is a low correlation, i.e. those blacks scoring high on the written exam do not score as relatively high on the other components, these other components would operate in a racially disparate manner. * * *

Id. at 1396-98 (emphasis added; citations and footnotes omitted).

We went on to note

that all these elements of the promotional process, the oral interview, the performance appraisals, the chief's rating, and the relative weight of each component involve decisions made by white supervisors on the basis of largely subjective criteria and must therefore be closely scrutinized because of their susceptibility to discriminatory abuse.

Id. at 1398 (citation omitted).

We found that because the district court had used an incorrect focus in analyzing the statistical evidence and had not considered "the statistical evidence against the background of the evidence on racial harassment at the Little Rock Police Department," id., a remand was necessary.

On remand, the district court once again failed to focus on the "ranking aspect of the promotional system," and the "interrelationship of the component factors." It based its decision on the statistical evidence presented by LRPD, which "compared the average scores of blacks and whites on each component." See Gilbert III, mem. op. at 14-17. This was contrary to this Court's instructions on remand. See Gilbert II, 722 F.2d at 1398.

The appellants' statistical evidence on remand was consistent with our directions, in that it focused on the critical factor--achieving a high ranking on the promotion list. Appellants first compared the relative performance of the black and white officers on the various components of the system, concluding that only the oral component adversely affected the black officers. Then, in order to determine the effect of the oral scores on the ranking of the black officers, they compared the "aggregate" scores, which combined the written, seniority, and, where applicable, performance appraisal points with the oral scores. For purposes of comparison, they divided the officers into six subgroups based on their average scores--an upper one-third, middle one-third, and lower one-third of both blacks and whites.

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