Chicago Teachers Union, Local No. 1 v. Bd. of Education of the City of Chicago

Dist Ct. erred in denying plaintiffs-Chicago Public School teachers’ motion to certify class in Title VII, section 1981 and section 1983 action alleging that defendant-School Board’s decision to reconstitute 10 schools by displacing 51% African-American tenured teachers was racially discriminatory, where Africa-American teachers comprised just 27% of overall teacher population. While Dist. Ct. believed that plaintiffs had failed to show existence of common question of law or fact because decisions as to each school was based on subjective factors about school performance, record showed that defendant utilized same objective criteria in first two steps of decision-making process to identify schools for reconstitution, and defendant's use same selection criteria by same decision-makers qualified instant case for class action treatment under Rule 23(b)(3). Moreover, Ct. found that instant case qualified for class action treatment under Rule 23(b)(2), where plaintiff also sought declaratory judgment relief that did not request any monetary or individual relief, and where plaintiff sought same declaratory and injunctive relief for entire class.