Charles A. Iadimarco v. Marvin T. Runyon, Postmaster General
1999 U.S. App. LEXIS 22029, 76 Empl. Prac. Dec. (CCH) 46,073, 190 F.3d 151 (1999)
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Rule of Law:
A plaintiff alleging a "reverse discrimination" claim under Title VII is not required to establish 'background circumstances' supporting the suspicion that the defendant is an unusual employer who discriminates against the majority. Instead, the plaintiff can establish a prima facie case by presenting sufficient evidence for a reasonable fact-finder to conclude that the employer treated the plaintiff less favorably than others based on a protected characteristic.
Facts:
- In 1992, the United States Postal Service underwent a reorganization, requiring employees to apply for available positions.
- Charles Iadimarco, a White male, applied for the position of Manager of In-plant Support at the Monmouth facility.
- Robert Towler, the selecting official, rated applicants using a 'knowledge, skills and abilities' (KSA) matrix, and Iadimarco was one of only three candidates to receive a 'superior' rating in every category.
- After the other two top-rated candidates were placed in other roles, Iadimarco became the only remaining applicant with a perfect KSA rating.
- Towler's supervisor, Henry Pankey, had previously issued a 'diversity memo' instructing managers to give 'very serious consideration' to diversity when filling vacancies.
- Instead of promoting Iadimarco, Towler reposted the position and ultimately selected Toni Williams, a Black female.
- Williams' application was submitted after the deadline had passed, and she was never evaluated using the KSA matrix.
- Iadimarco also alleged he was told an engineering degree was a prerequisite for the job, which he possessed but Williams did not.
Procedural Posture:
- Charles Iadimarco initiated a proceeding before the Equal Employment Opportunity Commission (EEOC).
- An Administrative Law Judge found that Iadimarco had been the victim of illegal discrimination.
- The EEOC rejected the judge's findings, concluding that Iadimarco failed to establish a prima facie case.
- Iadimarco filed a complaint in the U.S. District Court for the District of New Jersey, alleging racial discrimination under Title VII.
- The District Court granted summary judgment in favor of the United States Postal Service.
- Iadimarco, as appellant, appealed the summary judgment ruling to the U.S. Court of Appeals for the Third Circuit.
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Issue:
Does a plaintiff alleging 'reverse discrimination' under Title VII need to establish 'background circumstances' suggesting the defendant is an unusual employer who discriminates against the majority in order to establish a prima facie case of employment discrimination?
Opinions:
Majority - McKee
No. A plaintiff alleging 'reverse discrimination' under Title VII is not required to establish 'background circumstances' to make out a prima facie case. Instead, a plaintiff can establish a prima facie case by presenting sufficient evidence for a reasonable fact finder to conclude that the employer treated the plaintiff less favorably than others because of a protected trait such as race. The court rejected the 'background circumstances' test—used by several other circuits—as being 'problematic and unnecessary,' finding it vague, prone to confusion, and likely to impose a heightened burden on majority plaintiffs, which contradicts the purpose of the McDonnell Douglas framework. The court found Iadimarco presented sufficient evidence of discrimination to establish his prima facie case and to raise a genuine issue of material fact as to whether the Postal Service's stated reason for hiring Williams was pretextual. This evidence included Iadimarco's superior qualifications, procedural irregularities in the hiring process, Pankey's 'diversity memo,' and inconsistent statements by the hiring manager.
Analysis:
This decision significantly clarifies the standard for reverse discrimination claims within the Third Circuit by explicitly rejecting the 'background circumstances' test adopted by several other federal circuits. By aligning the prima facie requirements for all plaintiffs regardless of their majority or minority status, the court lowers the initial evidentiary bar for reverse discrimination plaintiffs in its jurisdiction. This precedent makes it easier for such cases to survive summary judgment, emphasizing that Title VII provides equal protection against discrimination for all individuals without imposing special or heightened pleading standards on any particular group.
