History
  • No items yet
midpage
523 F. App'x 19
2d Cir.
2013
Read the full case

Background

  • Abdul-Hakeem filed a 42 U.S.C. § 1983 Equal Protection claim against supervisors Parkinson and McCarthy at the Connecticut Superior Court.
  • The District Court granted summary judgment for the defendants on January 26, 2012.
  • The court held plaintiff failed to show disparate treatment and identified seven alleged comparators without evidence they were similarly situated.
  • The court clarified EP claims under state action resemble Title VII claims and require a prima facie showing with a discriminatorily motivated action.
  • The Second Circuit conducted de novo review and affirmed based on lack of evidence that comparators were similarly situated or that conduct disadvantaged Abdul-Hakeem.
  • The court concluded there was no inference of racial discrimination given the absence of similarly situated individuals outside the protected class.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether EP discrimination was shown Abdul-Hakeem alleges race-based discrimination by supervisors. Parkinson and McCarthy argue no similarly situated comparator demonstrated discriminatory intent. Affirmed; no prima facie evidence of discrimination.

Key Cases Cited

  • Brown v. City of Syracuse, 673 F.3d 141 (2d Cir. 2012) (equal protection requires equal treatment of similarly situated persons)
  • Feingold v. New York, 366 F.3d 138 (2d Cir. 2004) (EP claim parallels Title VII principles under color of state law)
  • Demoret v. Zegarelli, 451 F.3d 140 (2d Cir. 2006) (EP claim framework and discriminatory intent considerations)
  • Sassaman v. Gamache, 566 F.3d 307 (2d Cir. 2009) (prima facie Title VII analysis for employment discrimination)
  • Ruiz v. Cnty. of Rockland, 609 F.3d 486 (2d Cir. 2010) (disparate treatment requires similarly situated comparator)
  • Burg v. Gosselin, 591 F.3d 95 (2d Cir. 2010) (summary judgment standard: no genuine dispute of material fact)
  • Winfield v. Trottier, 710 F.3d 49 (2d Cir. 2013) (summary judgment standard and inference principles in the circuit)
Read the full case

Case Details

Case Name: Abdul-Hakeem v. Parkinson
Court Name: Court of Appeals for the Second Circuit
Date Published: Jun 21, 2013
Citations: 523 F. App'x 19; 12-748-cv
Docket Number: 12-748-cv
Court Abbreviation: 2d Cir.
Log In
    Abdul-Hakeem v. Parkinson, 523 F. App'x 19