Kendale L. Adams v. City of Indianapolis
2014 U.S. App. LEXIS 2115
| 7th Cir. | 2014Background
- Related cases allege discriminatory promotion practices by Indianapolis Metropolitan Police Department and Indianapolis Fire Department.
- Promotions were based on composite scores from 2007 (police) and 2008 (fire) testing protocols.
- First suit: 26 police officers and 10 firefighters claimed disparate treatment and disparate impact; district court dismissed several claims.
- Plaintiffs sought to amend; district court delayed ruling and later denied second amendment as untimely/futile.
- A second suit by 20 officers challenged 2010–2011 promotions; district court dismissed as res judicata; appeals consolidated.
- Court affirms in both appeals, upheld dismissal of disparate-impact and disparate-treatment claims, and preclusion of the second suit.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether pleading-stage dismissal of disparate-impact claims was proper | Plaintiffs contend district court erred by dismissing disparate-impact claims at pleadings stage. | City argues claims fail under Twombly/Iqbal and lack factual support tying testing to impact. | Affirmed; claims lacked factual content to show impact. |
| Whether leave to amend was properly denied | Plaintiffs argue they should be allowed to amend to address defects. | City contends scheduling order deadlines and futility bar amendment. | Affirmed; no abuse of discretion; amendment futile. |
| Whether summary judgment on disparate-treatment claims was proper | Plaintiffs contended there was evidence of intentional discrimination or pretext. | City showed legitimate, non-discriminatory testing-based promotions; plaintiffs failed to show pretext. | Affirmed; City entitled to summary judgment. |
| Whether second suit was barred by res judicata or collateral estoppel | Second suit attacked different promotion cycles and list. | Same core facts and final judgment in first suit; preclusion applies. | Affirmed; second suit barred by preclusion. |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (U.S. 2007) (pleading must allege plausible facts, not mere conclusory statements)
- Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (plausibility standard governs pleading sufficiency)
- National Railroad Passenger Corp. v. Morgan, 536 U.S. 101 (U.S. 2002) (each discrete act starts a new time limit for filing charges)
- Watson v. Fort Worth Bank & Trust, 487 U.S. 977 (U.S. 1988) (disparate-impact theory may apply to subjective and biased practices)
- Wards Cove Packing Co. v. Atonio, 490 U.S. 642 (U.S. 1989) (facially neutral practice may be liable under disparate impact)
- Bennett v. Roberts, 295 F.3d 687 (7th Cir. 2002) (disparate-impact claim exists even when practice is neutral on its face)
- Ledbetter v. Goodyear Tire & Rubber Co., 550 U.S. 618 (U.S. 2007) (statutory timing considerations for compensation-related claims)
- Pacheco v. Mineta, 448 F.3d 783 (5th Cir. 2006) (exhaustion of administrative remedies for disparate-impact claims must be adequate)
- McClain v. Lufkin Industries, Inc., 519 F.3d 264 (5th Cir. 2008) (disparate-impact pleading deficiencies highlighted)
- Alioto v. Town of Lisbon, 651 F.3d 715 (7th Cir. 2011) ( Rule 16(b)(4) good-cause standard governs extension of deadlines)
- Matrix IV, Inc. v. Am. Nat’l Bank & Trust Co. of Chi., 649 F.3d 539 (7th Cir. 2011) (standard for claim preclusion and related preclusion doctrines)
- Morgan v. National Railroad Passenger Corp., 536 U.S. 101 (U.S. 2002) (identifies discrete discriminatory acts as timely or untimely)