Whitfield v. International Truck and Engine Corp.

Dist. Ct. erred in entering judgment in favor of defendant-employer in Title VII action alleging that defendant failed to hire plaintiff for electrician position on account of his African-American race. Dist. Ct. gave implausible explanation for why term “black” was contained in cover sheet of plaintiff’s personnel file, and Dist. Ct. improperly ignored extensive evidence of racially hostile work environment. Fact that defendant had hired one African-American electrician near time of plaintiff’s application did not foreclose plaintiff’s claim where: (1) said applicant, who had extensive experience, was finally hired after her application had been pending for two years; (2) 11 white electricians had been hired during same period; and (3) said applicant was first African-American electrician that defendant had hired in decades. Moreover, Dist. Ct. could not have made finding as to race-neutral reason for defendant’s failure to hire plaintiff, where defendant had failed to identify relevant decision-maker, and Dist. Ct.’s finding that defendant wanted electricians with certain type of experience was not supported by evidence showing that certain white electricians were hired without such experience.