Reynolds v. Barrett, No. 10-4208 (2d Cir. 2012)Annotate this Case
In 1986, minority inmates commenced a class action, alleging racial discrimination in housing, job assignment, and discipline. The trial judge found a “pattern of racism” and, in 1993, issued a decision requiring that the percentage of minority inmates in “preferred” jobs, including jobs in the print shop, correspond to the percentage of minority inmates in the general prison population. In 1999, plaintiffs, inmates formerly employed in the print shop, filed complaints alleging racial discrimination by civilian supervisors and prison administrators. After four years of discovery, plaintiffs sought to file an amended class action complaint. In addition to claims under 42 U.S.C. 1981, 1983, 1985, and 1986, the complaint claimed violations of the earlier order, and the state Human Rights Law and constitution. Plaintiffs contended that the pattern-or-practice method of proof used in Title VII class actions could be employed against individual defendants. The court denied class certification and leave to amend and analyzed plaintiffs’ individual complaints under the McDonnell Douglas burden-shifting framework generally employed in assessing individual disparate treatment claims under Title VI and granted defendants summary judgment on individual claims. The Second Circuit affirmed; the pattern-or-practice framework is ill-suited to establish liability of individual defendants named in the proposed amended complaint.