Lou Michels and Rod Satterwhite are partners in the Labor & Employment group at McGuireWoods LLP. Both handle employment litigation on behalf of employers, and advise companies on employment issues regularly.
posted on Friday, April 13, 2007 11:39 AM by Lou Michels

Class Action Trend -- Demotion / Promotion / Hirings / Internal Practices

    The recent settlement of Federal Express's 9th Circuit race discrimination case, for more than $53 million, points to an increasing trend in the class action arena -- suits based on claims that discriminatory internal practices permeate the entire employment decision making structure of a company and are reflected in disparate hiring, promotion, demotion or discipline actions. 

     This particular case, filed in 2003 in Northern California (what a surprise), alleged a pattern of race discrimination against blacks and Hispanics through a disproportionate assignment of minorities to part-time or so-called "casual" positions, versus full-time jobs.  The suit also alleged that minorities were provided with fewer promotions than non-minority employees, disciplined more frequently for petty offenses, and paid less over all.

     Although the settlement is gigantic, it is probably miniscule compared to the cost of defending a certified class of tens of thousands of employees in different jobs, across different stores and management teams.  In fact, once a court certifies such a class, it becomes almost cost prohibitive for an employer to backtrack through the myriad of employment decisions related to just the class representatives to try to prepare a defense.

     So the lesson to all of us now is to beware of employment practices that might impose some kind of a statistical glass ceiling on certain groups.   Some federal, and many state, judges seem more than willing to certify classes comprised of wildly disparate individual cases, as long as an over-all trend is alleged and can be supported with relatively limited evidence.  These kinds of suits also effectively discourage the kind of decentralized decision-making used by many companies given current improvements in communication.   The existence of a corporate human resources department with arguable responsibility for company policies and their implementation can be used as evidence to defeat a claim that individual store managers were responsible for the employment decisions at issue.  The message is clear -- monitor your activities companywide or face a substantial risk of multi-plaintiff or class action litigation. 

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