Baylie v. Federal Reserve Bank of Chicago
United States Court of Appeals for the Seventh Circuit
476 F.3d 522 (7th Cir. 2007)
A class of Federal Reserve Bank employees sued under Title VII for race, sex, and age discrimination, but the district court de-certified the class, leaving two individual plaintiffs (plaintiffs) to pursue their own claims. Their expert's regression analysis of five years of non-managerial promotions found black employees had a 0.20 probability of promotion compared to 0.27 for white employees, meaning the average white worker received roughly one extra promotion every twenty years compared to the average black worker. The plaintiffs argued this statistical showing alone made out a prima facie case of individual disparate treatment; the district court disagreed and granted summary judgment for the Bank, and the plaintiffs appealed.
Whether statistical analysis is better suited for proving claims of systemic disparate treatment than claims of individual disparate treatment under Title VII.