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The U.S. Court of Appeals for the Second Circuit has upheld dismissal of a case brought by a black lawyer against Akin Gump Strauss Hauer & Feld who claimed she was fired as an associate because of her race. Tameka Simmons claimed in her civil rights lawsuit that a slump in the economy in 2009 was used by Akin Gump as a pretext for a race-based firing. But the circuit, by summary order in Simmons v. Akin Gump, 11-4480, said the deep recession that began in 2008 and its effect on Akin Gump’s legal business drove layoffs and was not used as cover for dismissing Simmons.

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