The Sixth Circuit found June 6, 2011 that a Memphis firefighter failed to prove the prima facie case of reverse race discrimination in a § 1981 action against the City. The Court declined to address the “heightened pleading standard” that applies to reverse discrimination cases, saying instead that the plaintiff had failed to show that he was qualified or that similarly situated non-white employees were treated more favorably, which constitutes two of the prima facie elements.
By: Chelsea Long