Meditz v. City of Newark
2011 U.S. App. LEXIS 19670
| 3rd Cir. | 2011Background
- Meditz, a white male, applied in April 2007 for Housing Development Analyst in Newark and was rejected in July 2007 because he resided in Rutherford.
- Newark requires non-uniformed employees to reside in the City, with waivers for certain positions; 185 non-uniformed employees live outside Newark in 82 municipalities.
- Uniformed employees must reside in Newark during training but may move out after; waivers reflect broader residency flexibility.
- Meditz provided publicly available statistical data showing lower white, non-Hispanic representation among Newark’s non-uniformed employees than in Newark’s population and related labor markets.
- District Court granted summary judgment for Newark, concluding Meditz failed to prove a prima facie disparate impact and that the relevant labor market did not extend beyond Newark; Third Circuit reverses in part and remands for further proceedings.
- Court will determine proper relevant labor market and apply correct statistical and business-necessity standards on remand.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Newark’s residency rule has a disparate impact on whites, non-Hispanics. | Meditz contends the rule reduces white, non-Hispanic representation in Newark’s non-uniformed workforce. | Newark argues statistics do not show a significantly discriminatory pattern. | Remanded; summary judgment improper on the disparate-impact claim. |
| How to define the relevant labor market for the disparate-impact analysis. | Six-county surrounding labor market should be used. | City limits may be adequate for labor-market definition. | Remanded to apply Harrison criteria to define the labor market. |
| Whether the statistics meet a prima facie showing of disparate impact. | Statistical disparities show under-representation and causation. | Disparities alone are insufficient without proper market and causation analysis. | Remanded for proper statistical methodology, including standard-deviation analysis. |
| What standard governs the business-necessity defense post-CR Act. | District Court used Harrison’s diluted standard. | Newark offered business-necessity justification. | On remand, apply El v. SEPTA standard (minimum job qualifications) rather than Harrison’s dilution; assess nexus to job performance. |
| Should causation be addressed in linking residency policy to job opportunities. | Residency policy causally affects hiring of whites. | If labor market aligns with residency, causation is not shown by内race comparison alone. | Remanded to analyze causation with proper labor-market parameters. |
Key Cases Cited
- Hazelwood School Dist. v. United States, 433 U.S. 299 (U.S. Supreme Court 1977) (statistical disparities may establish prima facie case; importance of appropriate labor market)
- Watson v. Fort Worth Bank & Trust, 487 U.S. 977 (U.S. Supreme Court 1988) (statistical evidence can support disparate impact claims; must show causation)
- Griggs v. Duke Power, 401 U.S. 424 (U.S. Supreme Court 1971) (neutral employment practices can have discriminatory effect; impact-based analysis)
- Dothard v. Rawlinson, 433 U.S. 321 (U.S. Supreme Court 1977) (requires showing of statistically significant impact on protected class)
- Wards Cove Packing Co. v. Atonio, 490 U.S. 642 (U.S. Supreme Court 1989) (business-necessity defense narrowed; later abrogated by Civil Rights Act of 1991 in El,)
- El v. SEPTA, 479 F.3d 232 (3d Cir. 2007) (reinstates pre-Wards Cove approach: business-necessity must reflect job qualifications; justify policies with adequate nexus)
- Harrison v. City of Harrison, 940 F.2d 792 (3d Cir. 1991) (defines relevant labor market factors; approves district-court methodology for residency cases (within Harrison’s context))
- Bayonne, N.A.A.C.P. v., 134 F.3d 113 (3d Cir. 1998) (causation in disparate-impact cases is a fact issue; requires showing that practice caused impact)