McCleary-Evans v. Maryland Department of Transportation
United States Court of Appeals for the Fourth Circuit
780 F.3d 582 (2015)
Dawnn McCleary-Evans (plaintiff) applied for two positions with the Maryland Department of Transportation (DOT) (defendant) and was not hired. She sued under Title VII, alleging the hiring managers were biased toward white men and had predetermined not to hire her. Her complaint showed she was qualified but did not allege the people actually hired were less qualified than she was. The district court dismissed the complaint, reasoning she was required to plead a prima facie case of discrimination under Bell Atlantic Corp. v. Twombly and had failed to do so. McCleary-Evans appealed, arguing the court used the wrong standard.
Whether a plaintiff must plead a prima facie case of discrimination to survive a motion to dismiss for failure to state a claim.