Meditz v. City of Newark, No. 10-2442 (3d Cir. 2011)Annotate this Case
Plaintiff, a white male, applied for the position of Housing Development Analyst in Newark. He was rejected because he lived in Rutherford; Newark has a residency requirement for non-uniformed employees. Plaintiff claimed the rule had a disparate impact on white, non-Hispanics because Newark's population does not reflect the racial make-up of the relevant labor market in the surrounding area. In a suit under Title VII, 42 U.S.C. 2000e-2(a)(1),the district court entered summary judgment in favor of the city. The Third Circuit reversed. Factual issues exist as to how to define the appropriate relevant labor market. Even if the city of Newark itself is the relevant labor market, the court erred in its statistical analysis and applied an incorrect standard when analyzing the business necessity defense.