Amini v. City of Minneapolis
2011 U.S. App. LEXIS 13641
| 8th Cir. | 2011Background
- Amini, born in Afghanistan, applied for MPD officer in 2006; his file shows Jakarta? (ignore) He ranked 63/83 after scoring 83.98 total.
- The hiring process uses an eligibility list created from fitness, oral exam, veterans points, then background investigations.
- Background summaries use candidate numbers; names, race, or national origin are omitted in the summaries.
- Panel ranks candidates with select/non-select/reservations; top candidates are approved for background and conditional offers.
- Amini’s background revealed a 1994 suspect status, two written reprimands, and a 1999 resignation in lieu of termination; he denied these during interview.
- Lubinski and the roundtable panel relied on temperament concerns to justify not hiring Amini; Amini was second on the eligible list but not selected.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Prima facie showing of discrimination | Amini qualified; minority status triggered presumptives | Amini qualified; nondiscriminatory reason exists | Amini qualified; City proffered nondiscriminatory reason |
| Pretext for discrimination | Record shows discriminatory motive by Caspers | Reasons grounded in facts; temperament concerns supported | No basis to find pretext |
| Use of subjective criteria in hiring | Subjectivity indicates bias | Subjective evaluation permissible if non-discriminatory | Subjective criteria not inherently discriminatory given comparable qualifications |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (burden-shifting framework for discrimination)
- Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (2000) (pretext evidence sufficient for denial of summary judgment)
- Torgerson v. City of Rochester, 643 F.3d 1031 (8th Cir. 2011) (prima facie/disparate treatment standard; pretext analysis)
- Rodgers v. U.S. Bank, N.A., 417 F.3d 845 (8th Cir. 2005) (similarly situated standard; pretext assessment)
- Chambers v. Metro. Prop. & Cas. Ins. Co., 351 F.3d 848 (8th Cir. 2003) (caution against using subjective criteria; not discriminatory per se)
- Staub v. Proctor Hosp., 131 S. Ct. 1186 (2011) (cat's paw liability for discriminatory bias by a non-decision-maker)