The United States District Court for the District of Massachusetts recently granted summary judgment for the defendant supervisory employees on a six count complaint, alleging claims of discrimination based on race, violations of the federal and state Civil Rights Act, and assorted state contract law claim filed by two employees, city police officers.
Plaintiffs, black police officers, alleged that they were given disadvantageous transfers out of an elite unit within the Boston Police Department in retaliation for having raised concerns about racially hostile attitudes by colleagues within the unit. They also alleged that the decision to transfer them was the product of a racially biased conspiracy between superior officers. Their claims were brought against their direct supervisors and the City of Boston.
The Defendant supervisory officers denied the Plaintiffs’ claims. They produced evidence that when concerns were raised in the unit with regard to racial tensions and hostilities, they and the City took immediate action to address those concerns, and did so successfully. The Defendants also demonstrated that the Plaintiffs were transferred due to legitimate and serious job related deficiencies in performance, and that there was no evidence that the named supervisory Defendants took any adverse job action against the Plaintiffs.
The United States District Court agreed, and issued judgment for the Defendants on every claim in the complaint. The Court found that Plaintiffs failed to show that any action taken by any Defendant was impermissibly motivated by racial bias or retaliatory motive, and concluded that there was nothing improper about supervisors communicating their dissatisfaction with Plaintiffs’ job performance to their superiors. In fact, the Court found that evaluating officers under their command was an integral part of the Defendants’ duties as police sergeants. The Court also found that the job critiques were legitimate, nondiscriminatory reasons for the transfers. The remaining state law claims were dismissed because Plaintiffs failed to produce any evidence in support of those legal theories.