Reynolds v. Barrett Gould v. Chamberlin
685 F.3d 193
| 2d Cir. | 2012Background
- This §1983 case involves Elmira Correctional Facility print shop discrimination against non-Caucasian inmates.
- Former Elmira inmates Reynolds and Gould sued multiple prison officials alleging race-based adverse actions; Mack and Ponder joined later.
- Plaintiffs proposed an amended class action asserting a pattern or practice of discrimination and disparate impact in the print shop from 1994–present.
- District court granted summary judgment on individual claims, denied class certification, and denied leave to amend; pattern-or-practice framework was not independently analyzed.
- Plaintiffs attempted to use a Title VII pattern-or-practice framework to obtain class-wide relief and to support liability of individual defendants; district court and court below addressed these issues.
- Guilfoyle’s statistical report was offered to show disparities but the court found statistics insufficient to establish individual liability and rejected pattern-or-practice for §1983 defendants.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| May pattern-or-practice framework apply to §1983 actions against individuals? | Reynolds and Gould argue pattern-or-practice applies. | Defendants contend framework is inapplicable to individual §1983 liability. | No; framework not applicable to individual §1983 defendants. |
| Can disparate-impact theory apply to §1983 equal-protection claims? | Plaintiffs seek liability based on disparate impact. | Disparate impact cannot establish §1981/§1983 liability without discriminatory intent. | Disparate impact cannot alone sustain §1981/§1983 claims; intent required. |
| Do statistics alone establish individual liability under §1983? | Statistics show widespread discrimination and support individual liability. | Statistics cannot prove which individual acted with discriminatory intent. | Statistics cannot establish which particular defendant discriminated; pattern-practice framework ill-suited. |
| Does Iqbal limit supervisory liability to individual actions? | Pattern-practice could identify responsible supervisors. | Iqbal requires personal involvement, not mere knowledge; supervisor liability is limited. | Iqbal forecloses automatic supervisory-liability through pattern evidence. |
Key Cases Cited
- Patterson v. Cnty. of Oneida, 375 F.3d 206 (2d Cir. 2004) (equal-protection and §1983 intentional-discrimination standards; intent required)
- Teamsters v. United States, 431 U.S. 324 (U.S. 1977) (pattern-or-practice framework; two-stage liability/remedy analysis)
- Robinson v. Metro-North Commuter R.R. Co., 267 F.3d 147 (2d Cir. 2001) (pattern-or-practice burden-shifting framework; civil rights discrimination)
- City of Cuyahoga Falls v. Buckeye Cmty. Hope Found., 538 U.S. 188 (U.S. 2003) (disparate-impact theories require intentional discrimination for §1983/EP claims)
- Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (individual-liability standard; vicarious liability not applicable to §1983)