Darensburg v. Metropolitan Transportation Commission
636 F.3d 511
| 9th Cir. | 2011Background
- Plaintiffs include racial minority bus riders, AC Transit, a labor union, and a community organization challenging MTC's RTEP.
- Plaintiffs allege that MTC’s emphasis on rail expansion over bus expansion discriminates against minorities who predominantly ride buses.
- RTEP was originally adopted in 2001 and amended in 2006, with rail projects receiving far more funding than bus projects.
- District court found a prima facie disparate impact for rail funding but required a less discriminatory, equally effective alternative, which Plaintiffs failed to show.
- Statistical data showed 66.3% of bus riders are minorities vs. 51.6% of rail riders, but the court assessed the impact at a regional, not project-specific, level.
- Appeal centers on whether the statistics properly establish a prima facie disparate impact and whether there was any intentional discrimination.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the statistics support disparate impact. | Darensburg argues minority bus riders are disproportionately affected by rail bias. | MTC contends the statistics misuse population bases and do not show impact on planned projects. | Disparate impact claim fails; statistics are unsound for this purpose. |
| Whether there is evidence of intentional discrimination. | Plaintiffs assert circumstantial evidence shows racial motivation in RTEP decisions. | MTC argues no substantial evidence of bias; the plan benefited minorities and whites alike in different contexts. | Intentional discrimination not proven; no triable issue on discriminatory motivation. |
Key Cases Cited
- New York City Environmental Justice Alliance v. Giuliani, 214 F.3d 65 (2d Cir. 2000) (appropriate statistical measure required for disparate impact)
- Robinson v. Adams, 847 F.2d 1315 (9th Cir. 1987) (general population statistics not a proxy for qualified job applicants)
- Inwood Laboratories, Inc. v. Ives Laboratories, Inc., 456 U.S. 844 (U.S. 1982) (standard for evaluating evidence in discrimination claims)
- Tsombanidis v. West Haven Fire Department, 352 F.3d 565 (2d Cir. 2003) (appropriate base population for disparate impact analysis)
- United States v. Hinkson, 585 F.3d 1247 (9th Cir. 2009) (en banc; standard for reviewing district court factual findings)
- Feeney, 442 U.S. 256 (U.S. 1979) (requires showing discriminatory impact and purpose for §1983 claims)