McCleary-Evans v. Maryland Department of Transportation, State Highway Administration
780 F.3d 582
| 4th Cir. | 2015Background
- Dawnn McCleary-Evans applied for two positions in the Maryland State Highway Administration's Environmental Compliance Division and was not hired; the positions were filled by non-Black candidates.
- She alleged Title VII discrimination (race and sex), claiming decisionmakers Gregory Keenan (white male) and Sonal Sangahvi (non-Black woman) were biased and had predetermined to hire white candidates.
- Complaint emphasized her qualifications but contained no factual allegations about the hired candidates' qualifications or specific discriminatory statements or actions during the interviews.
- The district court dismissed under Fed. R. Civ. P. 12(b)(6), finding the complaint failed to plead facts plausibly showing discrimination (particularly lacking facts to support an inference of discriminatory motive).
- On appeal, the Fourth Circuit majority affirmed: while Swierkiewicz bars a requirement to plead a McDonnell Douglas prima facie case, Twombly/Iqbal require factual allegations sufficient to make discrimination plausible, which were lacking here.
- Judge Wynn dissented in part, arguing McCleary-Evans pleaded sufficient factual context (who, when, what) under Swierkiewicz and that Twombly/Iqbal should not be over-applied to routine Title VII cases where key evidence lies with the employer.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether complaint must plead prima facie case (McDonnell Douglas) to survive 12(b)(6) | Swierkiewicz: no heightened prima facie pleading required | District court applied McDonnell Douglas elements; defendant argued dismissal appropriate for lack of facts | Court: plaintiff need not plead prima facie case, but must meet Twombly/Iqbal plausibility standard |
| Whether allegations sufficiently plead discriminatory motive (race and sex) | Alleged decisionmakers were non-Black and had a history/pattern of hiring non-Black candidates; alleged bias and preselection | Defendant: allegations are conclusory; selection of non-Black candidates alone is consistent with nondiscriminatory reasons | Held: allegations were conclusory/naked and did not plausibly show discriminatory motive; dismissal affirmed |
| Applicability of Twombly/Iqbal vs. Swierkiewicz in Title VII cases | Plaintiff: Swierkiewicz protects ordinary discrimination pleadings and requires only fair notice | Defendant: Twombly/Iqbal impose a plausibility requirement that applies generally | Held: Swierkiewicz remains good law but must be read with Twombly/Iqbal; plausible factual allegations required beyond labels/conclusions |
| Whether district court’s error in citing McDonnell Douglas affected outcome | Plaintiff: district court applied overly rigorous standard | Defendant: even under correct standard, complaint insufficient | Held: district court erred in analysis but reached correct result under Twombly/Iqbal plausibility test |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading requires factual matter to state a plausible claim; conclusory allegations insufficient)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (complaint must raise claim above speculative level; plausible-claim standard replaces Conley no-set-of-facts test)
- Swierkiewicz v. Sorema N.A., 534 U.S. 506 (2002) (Title VII plaintiff need not plead McDonnell Douglas prima facie case; fair notice suffices)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (established evidentiary framework for proving discrimination via prima facie case)
- Coleman v. Maryland Court of Appeals, 626 F.3d 187 (4th Cir. 2010) (pleading must provide plausible basis to infer discrimination under Twombly/Iqbal)