Mancini v. City of Providence
282 F. Supp. 3d 459
D.R.I.2017Background
- Mark Mancini, a Providence Police sergeant, injured his right knee on duty in Nov. 2010, was placed on injured-on-duty (IOD) and later on light duty; his light duty status was terminated and the City denied his accidental disability pension in 2012.
- Mancini sat for the June 2012 lieutenant promotional exam, scored 88.2 (7th of 16), and received 0 of 5 "service" points from Chief Colonel Hugh Clements, which kept him out of the top five promotion spots.
- Clements awarded service points after consulting command-staff recommendations; for Mancini the recommendations varied (several zeros, some higher scores) and Clements relied on that input and on concerns about leadership suitability for lieutenant.
- Mancini sued the City under FEPA, Rhode Island Civil Rights Act, ADA, and related statutes, alleging disability discrimination in failing to promote him; individual defendant Clements was previously dismissed as not individually liable under FEPA.
- On cross-motions for summary judgment, the Court evaluated whether Mancini established a prima facie ADA/disability discrimination claim and whether the City provided legitimate nondiscriminatory reasons and whether Mancini produced evidence of pretext.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Mancini was a "disabled" person under the ADA at time of exam | Mancini: his knee injury (chondromalacia) substantially limited walking, standing, bending, lifting, and working (affidavit) | City: plaintiff offered no admissible, specific medical evidence linking diagnosis to substantial limitations | Held: Mancini failed to prove disability or record-of-disability—self-serving affidavit conclusory and insufficient; prima facie disability not established |
| Whether plaintiff made out prima facie failure-to-promote claim | Mancini: he was qualified and was rejected in favor of others; was in protected class | City: even assuming disability, it proffered nondiscriminatory reasons for scoring and selection | Held: even assuming prima facie case, City met burden to articulate legitimate reasons; inference of discrimination rebutted |
| Whether City's stated reasons (service score process) were pretext for disability discrimination | Mancini: 0 score inconsistent with prior/future scores and with other IOD candidates; argues score was unfair and suggests discrimination | City: Clements relied on command-staff recommendations, viewed lieutenant as requiring greater leadership/engagement, and sought to make service points more meaningful | Held: Mancini failed to show pretext or discriminatory animus; evidence showed other IOD candidates received high scores, and plaintiff offered speculation rather than proof |
| Whether summary judgment for City was appropriate | Mancini: factual disputes exist as to qualifications and process warranting trial | City: record shows admissible reasons and no evidence of discriminatory motive | Held: Court granted City's cross-motion and denied Mancini's motion—no genuine issue of material fact on discrimination claim |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (burden-shifting framework for disparate-treatment claims)
- Texas Dep't of Cmty. Affairs v. Burdine, 450 U.S. 248 (employer's production burden to articulate nondiscriminatory reasons)
- Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (plaintiff may show pretext and discrimination; credibility assessment at trial)
- St. Mary's Honor Ctr. v. Hicks, 509 U.S. 502 (role of burden-of-production versus credibility)
- Mesnick v. Gen. Elec. Co., 950 F.2d 816 (First Circuit on plaintiff's burden to show pretext and animus)
- Rathbun v. Autozone, Inc., 361 F.3d 62 (prima facie elements for failure-to-promote)
- Ramos-Echevarría v. Pichis, Inc., 659 F.3d 182 (medical diagnosis alone insufficient; must show substantial limitation)
- Bailey v. Georgia-Pacific Corp., 306 F.3d 1162 (requirements for "regarded as" disability proof)
- Feliciano de la Cruz v. El Conquistador Resort & Country Club, 218 F.3d 1 (employer need only produce competent evidence of nondiscriminatory reason)
- McGarry v. Pielech, 47 A.3d 271 (R.I. reliance on federal McDonnell Douglas guidance)