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Doyle v. McLean County Health Dep't

August 16, 2007

DORA L. DOYLE, PLAINTIFF,
v.
MCLEAN COUNTY HEALTH DEPARTMENT, DEFENDANT.



The opinion of the court was delivered by: Michael M. Mihm United States District Judge

ORDER

Before this Court is Defendant McLean County Health Department's ("MCHD") Motion for Summary Judgment. For the reasons set forth below, MCHD's Motion for Summary Judgment [#45] is GRANTED.

JURISDICTION

This Court has jurisdiction over this matter pursuant to 28 U.S.C. § 1331 because the claims asserted in the Complaint present federal questions under Title VII, 42 U.S.C. § 2000e, et seq., and 42 U.S.C. § 1981.

FACTUAL BACKGROUND

MCHD is a local public entity located in Bloomington, Illinois, that provides various public health services to McLean County residents. In February 2004, MCHD was accepting applications to fill an opening for a Human Services Specialist position ("position"). Plaintiff, Dora L. Doyle ("Doyle"), an African-American female, submitted her resume to be considered for the position. She also filled out a job application while waiting for her interview.

The written job classification described the position as involving professional human service and communicable disease service work in implementing and coordinating HIV risk reduction, counseling and testing programs. The job classification presented the work related to the position as consisting of assessing clients' needs and making referrals for medical or human services, as well as conducting HIV education, outreach, and oversight of grant related activities.

The requirements for the position, as described in the job classification, included the following: a minimum of a bachelor's degree in social work, human services, public health education or a closely related area; two to three years of experience in providing social services to clients which involved health issues; or any equivalent combination of education and experience that would provide the noted knowledge, skills and abilities.

Communicable Disease Supervisor for the MCHD, Christine Shadewaldt ("Shadewaldt"), was responsible for interviewing applicants and selecting the top applicants for the position. Shadewaldt interviewed Doyle for the position. During each of the interviews, Shadewaldt utilized an interview checklist. After reviewing the applications and resumes and conducting interviews, Shadewaldt narrowed the group of applicants to three top candidates: Doyle, an African-American female, Deborah Webb ("Webb"), a Caucasian female, and Erin Johnson ("Johnson"), a Caucasian female. Shadewaldt selected Webb as the top candidate on the grounds that Webb possessed highly relevant prior experience including experience as an HIV counselor and grant writing ability. However, after she interviewed with Division Director, Karen Mayes ("Mayes"), Webb was ultimately not hired. According to Shadewaldt, Webb was not hired due to a lack of stability in Webb's previous employment.

After comparing the qualifications of the remaining two candidates, Doyle and Johnson, Shadewaldt ultimately determined that Johnson possessed stronger qualifications and selected Johnson as the top candidate. Johnson subsequently interviewed with Mayes, who agreed that Johnson was the better qualified candidate. Johnson was hired on March 29, 2004, at a salary of $30,048 per year. Doyle learned that she had not been selected for the position after contacting the MCHD.

Doyle filed a Charge of Discrimination with the EEOC on August 17, 2004, claiming that she had been discriminated against on the basis of her race. The EEOC ultimately issued Doyle a right to sue letter.

On May 27, 2005, Doyle filed this suit. She asserts two claims in her Complaint. In Count I, Doyle alleges that she was discriminated against because of her race, since a less qualified, non-Black applicant was selected over her. In Count II, titled "Unfair Hiring Behavior (Practice)," Doyle contends that the MCHD's practice of considering an applicant's "projected longevity in the position" has a disparate impact on African-Americans because it disproportionately disqualifies African-American applicants who, as a group, tend to have less stable work histories*fn1 . MCHD has now moved for summary judgment, and this Order follows.

DISCUSSION

Summary judgment is appropriate where "the pleadings, depositions, answers to the interrogatories, and admissions on file, together with affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to judgment as a matter of law." Fed. R. Civ. P. 56(c). The moving party may meet its burden of showing an absence of disputed material facts by demonstrating "that there is an absence of evidence to support the non-moving party's case." Celotex Corp. v. Catrett, 477 U.S. 317, 325 (1986). However, the record and all justifiable ...


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