Two white police sergeants sued the Village of Hazel Crest, claiming that the Village's promotion of an African American officer violated their civil rights based on race discrimination. The district court rejected the officers' claims, finding they did not present sufficient evidence that they were the object of unlawful discrimination. On appeal, the Seventh Circuit Court of Appeals affirmed the district court's decision in favor of the Village in Garofalo v. Village of Hazel Crest, (7th Cir. June 12, 2014).
The Court first looked at the demographics of Hazel Crest, which in 2010 was 85.2% black and approximately 10.2% white. The Court noted that despite these statistics, Hazel Crest had no black police officers in their supervisory ranks in 2005 when the new mayor stated he wanted to increase diversity in the department. In 2005, when Malcolm White was appointed deputy chief, four other alleged candidates for the position sued the Village. The Court's analysis focused on the issue of whether the plaintiffs presented any evidence suggesting that they had a chance at the promotion in the absence of the impermissible consideration of race. The court found none, and specifically held that the Village had presented non-discriminatory reasons for the decisions not to promote the plaintiffs, including that they suffered from lack of leadership, had a volatile and unstable personality, among others. As a result, the plaintiffs' claims of race discrimination failed.
Post Authored by Julie Tappendorf, Ancel Glink