Albright v. City of New Orleans

208 F. Supp. 2d 634, 2002 U.S. Dist. LEXIS 2391, 2002 WL 100579
CourtDistrict Court, E.D. Louisiana
DecidedJanuary 24, 2002
DocketCIV.A. 96-0679
StatusPublished

This text of 208 F. Supp. 2d 634 (Albright v. City of New Orleans) is published on Counsel Stack Legal Research, covering District Court, E.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Albright v. City of New Orleans, 208 F. Supp. 2d 634, 2002 U.S. Dist. LEXIS 2391, 2002 WL 100579 (E.D. La. 2002).

Opinion

FINDINGS OF FACT AND CONCLUSIONS OF LAW DAMAGES

BARBIER, District Judge.

Plaintiffs in this action are white New Orleans police officers who filed suit against the City of New Orleans (“the City”), the Superintendent of Police, the Mayor, and the City’s former Chief Administrative Officer, challenging the promotion policies of the New Orleans Police Department (“NOPD”) and claiming they were passed over for promotions to the ranks of sergeant and lieutenant on March 3, 1995, in favor of black officers. 1 After a one-day bench trial on the issue of liability, the Court issued its Findings of Fact and Conclusions of Law (Rec.Doc. 279) on June 26, 2001, 2 finding in favor of Plaintiffs and determining that the City had impermissi-bly considered race when selecting officers for promotion to the ranks of sergeant and lieutenant in March 1995, in violation of Title VII and the United States Constitution. 3 On December 17, 2001, a one-day *636 bench trial was conducted on the question of what damages Plaintiffs have suffered as a result of the City’s impermissible conduct. 4

Applicable Law

In formulating relief in employment discrimination cases, district courts have broad discretion in fashioning remedies as the equities of a particular case compel. United States v. Criminal Sheriff, Parish of Orleans, 19 F.3d 238, 239 (5th Cir.1994) (citing LeBlanc v. Southern Bell Tel. & Tel. Co., 460 F.2d 1228, 1229 (5th Cir.), cert. denied, 409 U.S. 990, 93 S.Ct. 320, 34 L.Ed.2d 257 (1972)). Where possible, courts should fashion remedies that serve the purposes of Title VII, i.e., remedies that compensate the victims of past discrimination and deter employers from the inclination to discriminate in the future. See Walsdorf v. Board of Com’rs for the East Jefferson Levee Dist., 857 F.2d 1047, 1054 (5th Cir.1988).

Section 706(g) of Title VII allows the district court to award “make-whole” relief to victims when an employer has engaged in illegal discrimination. 42 , U.S.C. § 2000e-5(g). Accordingly, the Court may order such affirmative action as may be deemed appropriate, including, but not limited to, reinstatement or hiring of employees, with or without back pay and/or any other equitable relief as the court deems adequate. Id. In addition, Title VII provides that the prevailing party may be awarded reasonable attorney’s fees, including expert fees, as part of the costs. 42 U.S.C. § 2000e-5(k).

42 U.S.C. § 1981a also provides that a complaining party under Title VII may recover compensatory and punitive damages. However, punitive damages are only available under Title VII when discrimination results from malicious or reckless indifference and are not available against governmental agencies or political subdivision. 42 U.S.C. § 1981a(b)(1). See also City of Newport v. Fact Concerts, Inc., 453 U.S. 247, 271, 101 S.Ct. 2748, 2762, 69 L.Ed.2d 616 (1981) (holding that in employment discrimination cases falling under 42 U.S.C. § 1983, municipalities are not subject to punitive damages for the actions of government officials).

With respect to recovery of compensatory damages in employment discrimination cases involving more than one plaintiff, the Fifth Circuit has stated that where multiple job applicants failed to secure a position, “only those who can prove that they would have gotten the position but for the discrimination can recover compensatory damages.” Arnold v. United States Department of the Interior, 213 F.3d 193, 197 *637 (5th Cir.2000). 5 While the Fifth Circuit’s pronouncement appears to fashion a strict rule in such cases, it must be borne in mind that the facts of Arnold are unique, and, that subsequent to the decision in Arnold, the Fifth Circuit suggested that its finding in that case may not be dispositive in every case involving multiple applicants competing for a limited number of positions. See Pratt v. City of Houston, 247 F.3d 601, 607 (5th Cir.2001).

In Pratt, the Fifth Circuit reversed the district court’s grant of summary judgment, finding that the two plaintiffs had presented enough evidence to create a question of fact regarding discriminatory motivation behind the City’s failure to promote them. Pratt, 247 F.3d at 607. In a footnote, the court recognized, however, that “even if there is a finding of prohibited discrimination, a remedy in [that] case may be problematic in that only one position was available.” Id. at n. 4. "While citing its previous statement in Arnold, the court suggested that, despite that pronouncement, an appropriate remedy could still be fashioned: “[W]e simply note the problem and leave it to the district court to resolve in the course of further proceedings.” Id. (Emphasis added). The Fifth Circuit, therefore, has not foreclosed the possibility that a district court may formulate an appropriate remedy in such a case.

Moreover, in employment discrimination cases involving multiple plaintiffs or class actions in other circuits, courts have applied a pro rata method for computing remedial relief when only a limited number of positions were available. See, e.g., United States v. City of Miami, 195 F.3d 1292, 1300 (11th Cir.1999); Ingram v. Madison Square Garden Center, Inc., 709 F.2d 807, 812 (2d Cir.1983); Hameed v. International Ass’n of Bridge, Structural, & Ornamental Iron Workers, Local Union No. 396, 637 F.2d 506, 519-21 (8th Cir.1980); Stewart v. General Motors Corp., 542 F.2d 445, 452-54 & n. 7 (7th Cir.1976). For example, in

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208 F. Supp. 2d 634, 2002 U.S. Dist. LEXIS 2391, 2002 WL 100579, Counsel Stack Legal Research, https://law.counselstack.com/opinion/albright-v-city-of-new-orleans-laed-2002.