Eugene Margerum v. City of Buffalo

28 N.E.3d 515, 24 N.Y.3d 721, 5 N.Y.S.3d 336
CourtNew York Court of Appeals
DecidedFebruary 17, 2015
Docket7
StatusPublished
Cited by49 cases

This text of 28 N.E.3d 515 (Eugene Margerum v. City of Buffalo) is published on Counsel Stack Legal Research, covering New York Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Eugene Margerum v. City of Buffalo, 28 N.E.3d 515, 24 N.Y.3d 721, 5 N.Y.S.3d 336 (N.Y. 2015).

Opinions

OPINION OF THE COURT

Chief Judge Lippman.

We hold that a notice of claim need not be filed for a Human Rights Law claim against a municipality and that plaintiffs should not have been granted summary judgment on the issue of liability involving discrimination as to civil service lists for Buffalo firefighters. We therefore remit for further proceedings.

In 1974, the United States sued the City of Buffalo in the Western District of New York. Among other things, the suit alleged that the written civil service examination developed by the New York State Department of Civil Service and used by the City to select entry-level firefighters and police officers had a discriminatory adverse impact against minorities. The District Court found that the City’s continued use of the State’s examination was part of a pattern or practice of discrimination against African-Americans, Hispanics and women in the fire and police departments (see United States v City of Buffalo, 457 F Supp 612 [WD NY 1978]). The District Court issued a “Remedial Decree” designed to remedy the effects of past discrimination, which imposed interim hiring ratios and affirmative recruitment efforts to increase the percentages of underrepresented classes. The decree was, for the most part, affirmed by the Second Circuit (633 F2d 643 [2d Cir 1980]).

In 1998, Members of Color Helping All (MOCHA), a not-for-profit organization of African-American firefighters, brought a putative class action against the City of Buffalo in the Western District of New York, alleging racially discriminatory practices [728]*728by the Buffalo Fire Department in violation of title VII of the Civil Rights Act of 1964 (42 USC § 2000e et seq.) and the New York Human Rights Law (MOCHA I). Among other things, the plaintiffs claimed that the 1998 examination used to select firefighters for promotion had an illegal disparate impact against African-American firefighters. MOCHA filed a second putative class action in 2003. This second suit alleged that the 2002 administration of the exam had the same discriminatory disparate impact as the 1998 exam {MOCHA II). About two years after the MOCHA II commencement, the City’s then Human Resources Commissioner, Leonard Matarese, decided to allow the promotion eligibility lists to expire between September 2005 and February 2006, before the four-year maximum duration had elapsed.

Thereafter, while MOCHA I and MOCHA II were still pending, this action was commenced. The 12 white firefighter plaintiffs on this appeal alleged that the City engaged in reverse, disparate treatment racial discrimination by permitting the promotion eligibility lists to expire before their maximum legal duration, thereby violating the Human Rights Law, the Civil Service Law, and the New York State Constitution.

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Cite This Page — Counsel Stack

Bluebook (online)
28 N.E.3d 515, 24 N.Y.3d 721, 5 N.Y.S.3d 336, Counsel Stack Legal Research, https://law.counselstack.com/opinion/eugene-margerum-v-city-of-buffalo-ny-2015.