DISCLAIMER: Any unofficial case summaries below are prepared by the clerk's office
as a courtesy to the reader. They are not part of the opinion of the court.
063554P.pdf 08/26/2008 Michael Martinez v. City of St. Louis
U.S. Court of Appeals Case No: 06-3554
U.S. District Court for the Eastern District of Missouri - St. Louis
[PUBLISHED] [Loken, Author, with John R. Gibson and Melloy,
Circuit Judges]
Civil case - Employment Discrimination. District court erred in
granting monetary and equitable relief for the City's hiring decisions
made before dissolution of the consent decree governing the hiring of
firefighters; compliance with a valid Title VII remedial consent decree
until it is dissolved is a complete defense to the pre-dissolution claims for
damages and other individualized relief; while dissolution of the decree
prospectively eliminated an affirmative defense to the reverse
discrimination claims asserted by plaintiffs, dissolution alone does not
establish that the City's post-dissolution hiring decisions were the
product of intentional race discrimination or adversely affected plaintiffs;
as the district court did not address the elements of the post-dissolution
hiring claims, the matter must be remanded for further proceedings on the
issue of liability and remedy; at this stage of the proceedings, an award of
attorneys' fees to plaintiffs would be premature.