Littlejohn v. City of New York
United States Court of Appeals for the Second Circuit
795 F.3d 297 (2015)
Dawn Littlejohn (plaintiff), an African American manager at the New York City Administration for Children's Services, complained to her supervisors about discriminatory practices during a merger process determining which employees would be retained, and was subsequently demoted to a lower-paying, non-management role; her replacement was white and, in Littlejohn's view, less qualified. She sued the city, her supervisors, and ACS (defendants) for race-based disparate treatment and retaliation for her discrimination complaints; the district court dismissed her complaint under Rule 12(b)(6), and she appealed.
Whether, absent direct evidence of employment discrimination, a plaintiff must allege facts in the complaint that plausibly support a minimal inference that the employer was motivated by discriminatory intent.