Bryant v. City of Chicago
United States Court of Appeals for the Seventh Circuit
200 F.3d 1092 (7th Cir. 2000)
The Chicago Police Department (defendant) hired a highly credentialed outside expert to design a rigorous, multi-part sergeant-to-lieutenant promotion exam based on extensive research into the lieutenant role; the exam's results, promoting the top 108 scorers, produced a stark racial disparity, with minorities representing less than 6% of promotions despite making up nearly a third of test-takers. Black and Hispanic sergeants (plaintiffs) sued under Title VII's disparate-impact theory; both sides agreed the statistics established a prima facie case, but the district court found the Department's expert testimony sufficient to establish the test's validity and job-relatedness, ruling for the Department, and the plaintiffs appealed.
Whether a professionally developed employment test that produces a statistically demonstrated disparate impact is lawful under Title VII if it constitutes a reasonable means of measuring job performance.