Plaintiff Failed To Raise Inference of Discrimination in Title VII Case

In Ruiz v. Cty. of Rockland, No. 09-0759, an action against a county for national origin and race discrimination under Title VII and the Equal Protection Clause, the Second Circuit affirmed summary judgment for defendant, holding that 1) the district court erred in finding that plaintiff was not qualified for his position based on evidence of plaintiff's misconduct; but 2) plaintiff failed to raise an inference of discrimination.

As the court wrote:  "Plaintiff Jorge Ruiz appeals the February 11, 2009 order of the United States District Court for the Southern District of New York (Eginton, J.) granting defendants County of Rockland and Mary Ann Walsh-Tozer summary judgment on plaintiff's action for national origin and race discrimination pursuant to Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e, et seq.; 42 U.S.C. § 1981; and the Equal Protection Clause of the Fourteenth Amendment pursuant to 42 U.S.C. § 1983. The district court concluded that Mr. Ruiz had failed to establish a prima facie case of discrimination. We agree that Mr. Ruiz failed to raise an inference of discrimination and we therefore affirm the decision of the district court. However, we wish to clarify the second prong of the prima facie case: whether Mr. Ruiz was qualified for his position. We conclude that the district court erred in finding that Mr. Ruiz was not qualified for his position based on the evidence of Mr. Ruiz's misconduct. Instead, the court should have evaluated such evidence in the context of defendants' legitimate, non-discriminatory reason for his termination."

Related Resources

• Full Text of Ruiz v. Cty. of Rockland, No. 09-0759