X

Thank you for sharing!

Your article was successfully shared with the contacts you provided.
Argued: September 19, 2000

Appeal from judgment of the United States District Court for the District of Connecticut (Gerard L. Goettel, Judge dismissing plaintiff’s age and sex discrimination claims on summary judgment. Affirmed in part, reversed in part.

Plaintiff Robert F. Byrnie appeals from a judgment of the United States District Court for the District of Connecticut, Gerard L. Goettel, Judge, dismissing his complaint alleging defendants Town of Cromwell Public Schools and Cromwell Board of Education (“Cromwell”) failed to hire him for a part time teaching position as an art teacher on the basis of his age, in violation of the Age Discrimination in Employment Act of 1967 (“ADEA”), 29 U.S.C. � 621 et seq., and on the basis of his gender, in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. � 2000e et seq. and Title IX of the Education Amendments of 1972, as amended, 20 U.S.C. � 1681 et seq. The district court dismissed Byrnie’s disparate treatment claims under both statutes on summary judgment on the grounds that Byrnie had failed to produce sufficient evidence to show that Cromwell’s nondiscriminatory reason for hiring another candidate was pretext. The district court also dismissed Byrnie’s disparate impact claims under both statutes on summary judgment because the statistical evidence offered by Byrnie of gender and age discrimination was insufficiently linked to any identifiable hiring practice or policy. On appeal, Byrnie contends summary judgment was inappropriate on his disparate treatment claims because unlawful discrimination could be inferred from a number of circumstances, including: the objective superiority of his paper credentials in comparison with the chosen candidate’s; the vague and conclusory nature of Cromwell’s business reason; and the destruction of documents made in connection with the hiring process. Byrnie also contends that summary judgment was inappropriate on his age-related disparate impact claim because he could allege a specific employment practice as the cause of statistical evidence indicating an age imbalance in Cromwell’s teaching hires. Summary judgment on his gender-related disparate impact claim was inappropriate, Byrnie argues, because he was prevented from alleging a cause for the statistical evidence showing gender imbalance among Cromwell’s teachers due to Cromwell’s destruction of documents. For the reasons below, we affirm the district court’s dismissal of Byrnie’s disparate impact claims but reverse with regard to Byrnie’s disparate treatment claims.

 
Reprints & Licensing
Mentioned in a Law.com story?

License our industry-leading legal content to extend your thought leadership and build your brand.

More From ALM

With this subscription you will receive unlimited access to high quality, online, on-demand premium content from well-respected faculty in the legal industry. This is perfect for attorneys licensed in multiple jurisdictions or for attorneys that have fulfilled their CLE requirement but need to access resourceful information for their practice areas.
View Now
Our Team Account subscription service is for legal teams of four or more attorneys. Each attorney is granted unlimited access to high quality, on-demand premium content from well-respected faculty in the legal industry along with administrative access to easily manage CLE for the entire team.
View Now
Gain access to some of the most knowledgeable and experienced attorneys with our 2 bundle options! Our Compliance bundles are curated by CLE Counselors and include current legal topics and challenges within the industry. Our second option allows you to build your bundle and strategically select the content that pertains to your needs. Both options are priced the same.
View Now
April 18, 2024
New York, NY

Join the industry's top owners, investors, developers, brokers & financiers at THE MULTIFAMILY EVENT OF THE YEAR!


Learn More
April 25, 2024
Dubai

Law firms & in-house legal departments with a presence in the middle east celebrate outstanding achievement within the profession.


Learn More
April 29, 2024 - May 01, 2024
Aurora, CO

The premier educational and networking event for employee benefits brokers and agents.


Learn More

Atlanta s John Marshall Law School is seeking to hire one or more full-time, visiting Legal WritingInstructors to teach Legal Research, Anal...


Apply Now ›

Lower Manhattan firm seeks a premises liability litigator (i.e., depositions, SJ motions, and/or trials) with at least 3-6 years of experien...


Apply Now ›

At NJM, a top-rated insurance company, we are seeking an Attorney on our Workers Compensation legal team with between 3 and 5 years of expe...


Apply Now ›
04/15/2024
Connecticut Law Tribune

MELICK & PORTER, LLP PROMOTES CONNECTICUT PARTNERS HOLLY ROGERS, STEVEN BANKS, and ALEXANDER AHRENS


View Announcement ›
04/11/2024
New Jersey Law Journal

Professional Announcement


View Announcement ›
04/08/2024
Daily Report

Daily Report 1/2 Page Professional Announcement 60 Days


View Announcement ›