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Elsa Gulino, Mayling Ralph and Peter Wilds, on Behalf of Themselves and All Others Similarly Situated, Nia Greene v. New York State Education Department, Defendant-Cross-Defendant-Appellee, Board of Education of the New York City School District of the City of New York, Defendant-Cross-Claimant-Appellee. Docket No. 03-9062-Cv

Citation: 460 F.3d 361Docket: 361

Court: Court of Appeals for the Second Circuit; August 17, 2006; Federal Appellate Court

Narrative Opinion Summary

This case involves a class action by African-American and Latino educators against the New York State Education Department (SED) and the New York City Board of Education (BOE), challenging the use of standardized tests for teacher certification under Title VII of the Civil Rights Act of 1964. The plaintiffs argued that the tests had a disparate impact on minority candidates. The district court found that while the tests had such an impact, they were job-related, thus protecting the defendants from liability under Title VII. The appellate court, however, disagreed with the district court's application of the 'interference' test, determining that SED was not an 'employer' under Title VII, but upheld BOE's status as an employer. The court identified errors in the district court’s validation of the Liberal Arts and Sciences Test (LAST), requiring a remand for further proceedings. The case underscores the complexity of determining employer status and validating employment tests under Title VII. The outcome was a vacated district court judgment and a remand for additional analysis, with SED dismissed from the claims while BOE remains liable under Title VII.

Legal Issues Addressed

Employer Status under Title VII

Application: The appellate court determined that SED was not an 'employer' under Title VII, reversing the district court's application of the 'interference' test.

Reasoning: The appellate court disagreed with the district court's application of this test, reversing the decision. It stated that SED does not qualify as an employer under any of the three tests, thereby dismissing the Title VII claims against it.

Job-Relatedness Requirement for Employment Tests

Application: The district court validated the Core Battery test as job-related, but the appellate court found errors in its reasoning regarding the LAST, requiring further analysis.

Reasoning: The district court found that the challenged tests, the Core Battery and the LAST, were job-related, leading to a judgment for the defendants. The appellants are only disputing the job-relatedness of the LAST.

Role of Local School Boards in Teacher Employment

Application: Local school boards in New York maintain substantial control over teacher employment decisions, including hiring and compensation, despite state oversight.

Reasoning: Local school boards have the authority to employ legally qualified teachers and to determine their compensation rates as outlined in New York Education Law.

Title VII Disparate Impact Claims

Application: The plaintiffs established a prima facie case of disparate impact due to the standardized tests' effect on minority candidates, but the defendants argued the tests were job-related.

Reasoning: Plaintiffs successfully established a prima facie case of disparate impact based on statistical evidence. The defendants countered with evidence that the tests were valid and relevant to the necessary skills for public school teachers.

Validation Standards for Employment Tests

Application: The appellate court identified errors in the district court's application of validation standards for the LAST, necessitating a remand for further proceedings.

Reasoning: Due to identified factual and legal errors, a remand is necessary, providing the new judge with clarity on the legal standards in this Circuit.