Woods v. City of Greensboro, No. 16-1044 (4th Cir. 2017)Annotate this Case
After BNT, a minority-owned television network, was granted and then denied an economic development loan from the City, BNT filed suit alleging, among other things, claims for racial discrimination under 42 U.S.C. 1981. The district court concluded that BNT's factual allegations were so insubstantial as to render its claim implausible, and therefore dismissed the complaint with prejudice. The Fourth Circuit held that the district court misinterpreted and misapplied the controlling pleading standard. In this case, the key issue was not whether the City would contract with a minority-owned business, but whether the City would contract with BNT on the same conditions and under substantially the same circumstances as it would with a nonminority-owned business. BNT has plausibly pled that the conditions under which the City was willing to grant it a loan were more stringent than those the City applied to similarly situated white-owned applicants. Therefore, the district court erred in dismissing BNT's claim of discrimination at the pleading stage. Accordingly, the Fourth Circuit reversed and remanded for further proceedings.