Adams v. City of Indianapolis, No. 12-1874 (7th Cir. 2014)
Annotate this CaseA large group of African-American police officers and firefighters sued the City of Indianapolis, alleging that the examination process it uses to rank candidates for promotion in the police and fire departments has a disparate impact on black candidates and is intentionally discriminatory. They filed lawsuits targeting promotion decisions made in successive promotion cycles starting inv2002, but most of the challenged decisions were based on scores generated by testing administered by the police department in 2008 and the fire department in 2007. The district court dismissed many of the claims as either time-barred or substantively flawed. The Seventh Circuit affirmed. Although the district court mistakenly assumed that allegations of intentional discrimination necessarily defeat a disparate-impact claim, here the disparate-impact claims fail because they are stated as legal conclusions, without any factual content to support an inference that the examination procedures caused a disparate impact on black applicants for promotion. The disparate-treatment claims lacked evidentiary support and were properly resolved on summary judgment. Although the second complaint concerns a different set of promotion decisions, it attacked the same eligibility list that was at issue in the first case and was, therefore, barred.
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