Case: United States v. City of Durham, North Carolina

1:24-cv-00838 | U.S. District Court for the Middle District of North Carolina

Filed Date: Oct. 7, 2024

Case Ongoing

Clearinghouse coding complete

Case Summary

This case is about enforcing Title VII of the Civil Rights Act. On October 7, 2024, the U.S. government brought a lawsuit against the City of Durham, North Carolina, in U.S. District Court for the Middle District of North Carolina. In its complaint, the government alleged the following facts: The Durham Fire Department (“FDF”), which is overseen by the city of Durham, used a multiple-choice and written test, the Comprehensive Examination Battery (“CEB”), to screen entry-level firefighter applic…

This case is about enforcing Title VII of the Civil Rights Act. On October 7, 2024, the U.S. government brought a lawsuit against the City of Durham, North Carolina, in U.S. District Court for the Middle District of North Carolina. In its complaint, the government alleged the following facts: The Durham Fire Department (“FDF”), which is overseen by the city of Durham, used a multiple-choice and written test, the Comprehensive Examination Battery (“CEB”), to screen entry-level firefighter applications. Applicants who scored less than 70% on the CEB did not advance in the screening process. Plaintiff argued that the CEB disproportionately affected black applicants’ employment prospects, even though the CEB was not meaningfully related to the job or otherwise necessary. There was a measurable difference in CEB outcome based on race: Around 37% of black test-takers failed the test, as opposed to around 11% of white test-takers who failed. Plaintiff also alleged that even for applicants who passed, however, there continued to be race-related discrimination: 32% of black applicants who passed the test and were eligible for an in-person interview did not receive one; only 14% of white applicants similarly positioned did not receive an interview invitation. Plaintiff also asserted that the CEB was not job-related, nor consistent with business necessity – even if the CEB were, however, plaintiff also reasoned that alternative selection procedures could have been used. Plaintiff set forth in its complaint that the city of Durham was in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e (“Title VII”), by engaging in a pattern of employment discrimination against black applicants. Plaintiff sought a court order mandating the following: that Durham no longer use written tests for entry-level firefighter positions if they have disparate racial impact and are not job-related nor otherwise do not meet the requirements of Title VII; provide remedial relief to people who had suffered individual loss as a result of the discrimination alleged in the complaint; and adopt any other non-discriminatory measures to correct the present effects of its discriminatory policies.

On the same day, the parties filed a joint motion for provisional approval and entry of consent decree. The parties had jointly negotiated a consent decree to resolve the litigation, which would require: (1) Durham replace the challenged CEB exam with new employment screening practices which comply with Title VII; and (2) Durham provide individual relief to eligible black applicants who were excluded from further consideration as entry-level firefighters due to the CEB. With respect to the first requirement, Durham agreed to not administer any written exam for use in selecting entry-level firefighters without the assent of the U.S. government or court approval, and to hire a Test Developer to explore other selection devices that would reduce or eliminate disparate racial impact on applicants. With respect to the second requirement, Durham agreed to pay $980,000 into a settlement fund, which would be used to compensate eligible claimants. A copy of the proposed consent decree is available on the Clearinghouse website. The parties asked the court to provisionally approve that agreement, to schedule a Fairness Hearing, and stay all deadlines in the litigation pending determination on the consent decree.

The matter was assigned to Judge Thomas D. Schroeder.

On December 16, 2024, a Motion Hearing was held. While a transcript of that hearing is not available to the Clearinghouse, the court ordered the parties to submit supplemental briefing, to address whether Ricci v. DeStefano, 557 U.S. 557, 585 (2009), applied in this matter. In Ricci, which involved a similar Title VII challenge to a written exam requirement for firefighter applicants, set a high standard that there must be a “strong basis in evidence” that without the race-based remedy, the organization would be liable under Title VII.

The American Alliance for Equal Rights, a non-profit member organization focused on racial discrimination issues, filed a motion for leave to file an amicus brief in opposition to the proposed consent decree and participate in oral arguments. The American Alliance for Equal Rights argued that this case directly implicates their interests, as the government’s theory of disparate-impact liability would force employers to inject race in employment decision-making processes. The court granted the organization leave to file.

The American Alliance for Equal Rights did submit its amicus brief on January 15, 2025. In that amicus brief, the organization argued that Durham currently used a race-neutral test. They argued that the consent decree would require the city to implement a race-based test, and urged the court to avoid granting such a remedy as the organization believed that would itself violate Title VII’s bar on intentional discrimination.

On January 15, 2025, plaintiff submitted the requested brief, on the applicability of Ricci. In that brief, plaintiff argued that (1) Ricci was distinguishable and that the court should be guided by United States v. North Carolina, 80 F.3d 574, 581 (4th Cir. 1999), which set a more lax fair-and-reasonable standard and which is controlling law in the Fourth Circuit, and (2) even if Ricci applied, there was sufficiently strong basis in evidence to support the U.S.’s prima facie case of disparate impact discrimination and the consent decree as it was formulated.

The court had not yet issued a decision on this matter. The U.S. government changed presidential administrations on January 20, 2025. Following that change in administration, on February 25, 2025, the U.S. government filed notice that it was voluntarily dismissing its claims in this matter. No further update has been made at this time.

Summary Authors

Keren Yi (4/7/2025)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/69231805/parties/united-states-v-city-of-durham-north-carolina/


Judge(s)
Attorney for Plaintiff

GIVEN, EMILY (North Carolina)

MAYER, REBECCA A. (North Carolina)

Attorney for Defendant

LAWS, SARAH (North Carolina)

Expert/Monitor/Master/Other

DICKEY, GILBERT (North Carolina)

DRAPER, PAUL RICKARD (North Carolina)

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Documents in the Clearinghouse

Document
2-4

1:24-cv-00838

Order

Oct. 7, 2024

Oct. 7, 2024

Order/Opinion
1

1:24-cv-00838

Complaint

Oct. 7, 2024

Oct. 7, 2024

Complaint
2

1:24-cv-00838

Joint Motion for Provisional Approval and Entry of Consent Decree

Oct. 7, 2024

Oct. 7, 2024

Pleading / Motion / Brief
2-2

1:24-cv-00838

Consent Decree

Oct. 7, 2024

Oct. 7, 2024

Order/Opinion
28

1:24-cv-00838

Notice of Voluntary Dismissal

Feb. 25, 2025

Feb. 25, 2025

Other

Docket

See docket on RECAP: https://www.courtlistener.com/docket/69231805/united-states-v-city-of-durham-north-carolina/

Last updated July 13, 2025, 10:30 a.m.

ECF Number Description Date Link Date / Link
1

COMPLAINT against CITY OF DURHAM, NORTH CAROLINA filed by UNITED STATES OF AMERICA. (GIVEN, EMILY) Modified on 10/8/2024 to correct party names. (sh) (Entered: 10/07/2024)

Oct. 7, 2024

Oct. 7, 2024

Clearinghouse
2

Joint MOTION for Provisional Approval and Entry of Consent Decree by United States. (Attachments: # 1 Memorandum in Support of Joint Motion, # 2 Exhibit A - Consent Decree, # 3 Appendices to Exhibit A - Consent Decree, # 4 Proposed Order)(GIVEN, EMILY) (Entered: 10/07/2024)

1 Memorandum in Support of Joint Motion

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2 Exhibit A - Consent Decree

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3 Appendices to Exhibit A - Consent Decree

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4 Proposed Order

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Oct. 7, 2024

Oct. 7, 2024

Clearinghouse
3

MEMORANDUM filed by Plaintiff UNITED STATES OF AMERICA re 2 Joint MOTION for Provisional Approval and Entry of Consent Decree filed by UNITED STATES OF AMERICA. (GIVEN, EMILY) (Entered: 10/07/2024)

Oct. 7, 2024

Oct. 7, 2024

RECAP
4

NOTICE of Attorney Appearance by attorney REBECCA A. MAYER on behalf of Plaintiff UNITED STATES OF AMERICA (MAYER, REBECCA) (Entered: 10/07/2024)

Oct. 7, 2024

Oct. 7, 2024

RECAP
5

NOTICE of Attorney Appearance by attorney ROBERT RICH on behalf of Plaintiff UNITED STATES OF AMERICA (RICH, ROBERT) (Entered: 10/08/2024)

Oct. 8, 2024

Oct. 8, 2024

RECAP

Case ASSIGNED to UNASSIGNED and MAG/JUDGE JOI ELIZABETH PEAKE. (sh)

Oct. 8, 2024

Oct. 8, 2024

PACER

CASE REFERRED to Standing Order 30. (sh)

Oct. 8, 2024

Oct. 8, 2024

PACER
6

NOTICE of Attorney Appearance by attorney ANNE MARIE TOSCO on behalf of Defendant CITY OF DURHAM, NORTH CAROLINA (TOSCO, ANNE) (Entered: 10/08/2024)

Oct. 8, 2024

Oct. 8, 2024

RECAP
7

Summons Issued as to CITY OF DURHAM, NORTH CAROLINA. (sh) (Entered: 10/08/2024)

Oct. 8, 2024

Oct. 8, 2024

RECAP

Motions Referred: RE: 2 Joint MOTION for Provisional Approval and Entry of Consent Decree, to MAG/JUDGE JOI ELIZABETH PEAKE (kg)

Oct. 15, 2024

Oct. 15, 2024

PACER

Case Reassigned to JUDGE THOMAS D. SCHROEDER. UNASSIGNED no longer assigned to the case. (km)

Oct. 18, 2024

Oct. 18, 2024

PACER

Motion Submitted to JUDGE THOMAS D. SCHROEDER: 2 Joint MOTION for Provisional Approval and Entry of Consent Decree. (ae)

Oct. 18, 2024

Oct. 18, 2024

PACER
8

NOTICE of Attorney Appearance by attorney SARAH LAWS on behalf of Defendant CITY OF DURHAM, NORTH CAROLINA (LAWS, SARAH) (Entered: 10/21/2024)

Oct. 21, 2024

Oct. 21, 2024

RECAP
9

NOTICE of Hearing: Motion Hearing set for 12/16/2024 at 10:00 AM in Winston-Salem Courtroom #2 before JUDGE THOMAS D. SCHROEDER. (ae) (Entered: 11/25/2024)

Nov. 25, 2024

Nov. 25, 2024

RECAP

Minute Entry for proceedings held before JUDGE THOMAS D. SCHROEDER in WS-2: Motion Hearing held on 12/16/2024 on 2 Joint MOTION for Provisional Approval and Entry of Consent Decree filed by UNITED STATES OF AMERICA. AUSA Rebecca Mayer and DOJ Trial Attorneys Emily Given and Robert Rich present for the Government. Attorney Ann Marie Tosco present for the City of Durham. Argument presented. Supplemental briefing to address the application, or not, of Ricci and if Ricci does apply, why there is a strong basis in evidence due within 30 days. Matter taken under advisement. (Court Reporter Briana Chesnut.) (ae)

Dec. 16, 2024

Dec. 16, 2024

PACER
10

Joint MOTION to Stay Case Management Deadlines by UNITED STATES OF AMERICA. Response to Motion due by 1/9/2025 (Attachments: # 1 Text of Proposed Order)(RICH, ROBERT) (Entered: 12/19/2024)

1 Text of Proposed Order

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Dec. 19, 2024

Dec. 19, 2024

RECAP

Motion Submitted to JUDGE THOMAS D. SCHROEDER: 10 Joint MOTION to Stay Case Management Deadlines. (ae)

Dec. 19, 2024

Dec. 19, 2024

PACER
11

Transcript of Proceedings held on 12/16/2024, before Judge Thomas D. Schroeder. Court Reporter Briana L. Chesnut, Telephone number 336-734-2514. Email: brinesbit@gmail.com. Transcript may be viewed at the court public terminal or purchased through the Court Reporter before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. NOTICE RE: REDACTION OF TRANSCRIPTS: The parties have 5 business days to file a Notice of Intent to Request Redaction and 21 calendar days to file a Redaction Request. If no notice is filed, this transcript will be made electronically available to the public without redaction after 90 calendar days. Transcript may be viewed at the court public terminal or purchased through the court reporter before the 90 day deadline. After that date it may be obtained through PACER. Redaction Request due 1/13/2025. Redacted Transcript Deadline set for 1/24/2025. Release of Transcript Restriction set for 3/24/2025. (bc) (Entered: 12/20/2024)

Dec. 20, 2024

Dec. 20, 2024

PACER
12

ORDER granting 10 Motion to Stay is GRANTED and that all case management deadlines, including the United States' deadline to serve the Summons and Complaint on the City of Durham, are stayed pending the courts resolution of the Parties' Joint Motion for Provisional Approval and Entry of Consent Decree. Signed by JUDGE THOMAS D. SCHROEDER on 12/20/2024. (at) (Entered: 12/20/2024)

Dec. 20, 2024

Dec. 20, 2024

RECAP
13

Consent MOTION to Exceed Word Limitation by UNITED STATES OF AMERICA. Response to Motion due by 1/31/2025 (Attachments: # 1 Text of Proposed Order)(GIVEN, EMILY) (Entered: 01/10/2025)

1 Text of Proposed Order

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Jan. 10, 2025

Jan. 10, 2025

RECAP

Motion Submitted to JUDGE THOMAS D. SCHROEDER: 13 Consent MOTION to Exceed Word Limitation. (ae)

Jan. 13, 2025

Jan. 13, 2025

PACER
14

MOTION for Leave to File Amicus Brief and Appear at Argument by American Alliance for Equal Rights. Response to Motion due by 2/4/2025 (Attachments: # 1 Proposed Amicus Brief, # 2 Text of Proposed Order)(DICKEY, GILBERT) (Entered: 01/14/2025)

1 Proposed Amicus Brief

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2 Text of Proposed Order

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Jan. 14, 2025

Jan. 14, 2025

RECAP
15

NOTICE of Attorney Appearance by attorney GILBERT DICKEY on behalf of Amicus American Alliance for Equal Rights (DICKEY, GILBERT) (Entered: 01/14/2025)

Jan. 14, 2025

Jan. 14, 2025

RECAP
16

Corporate Disclosure Statement. (DICKEY, GILBERT) (Entered: 01/14/2025)

Jan. 14, 2025

Jan. 14, 2025

RECAP

Motion Submitted to JUDGE THOMAS D. SCHROEDER: 14 MOTION for Leave to File Amicus Brief and Appear at Argument. (ae)

Jan. 15, 2025

Jan. 15, 2025

PACER
17

ORDER signed by JUDGE THOMAS D. SCHROEDER on 01/15/2025, that the motion (Doc. 13 ) is GRANTED. The word limit for the briefing the court requested regarding the applicability of Ricci v. Destefano, 557 U.S. 557 (2009), (Minute Entry Dec. 16, 2014), is increased to 9,000 words. (cc) (Entered: 01/15/2025)

Jan. 15, 2025

Jan. 15, 2025

RECAP
18

ORDER that the motion 14 is GRANTED in that American Alliance for Equal Rights is granted leave to file its brief as amicus curiae as a separate document forthwith. The court reserves decision on whether the Alliance shall be granted leave to present argument at any future hearing. See L.R. 7.5(f). Signed by JUDGE THOMAS D. SCHROEDER on 01/15/2025. (at) (Entered: 01/15/2025)

Jan. 15, 2025

Jan. 15, 2025

RECAP
19

Amicus Curiae BRIEF of the American Alliance for Equal Rights. (DICKEY, GILBERT) (Entered: 01/15/2025)

Jan. 15, 2025

Jan. 15, 2025

RECAP
20

Redacted BRIEF Regarding Applicability of Ricci v. DeStefano to Motion for Provisional Approval and Entry of Consent Decree. (Attachments: # 1 Exhibit 1 - Scherbaum Declaration, # 2 Exhibit 2 - Goldstein Declaration (redacted, # 3 Exhibit 3 - MDSP Order, # 4 Exhibit 4 - Lubbock Order, # 5 Exhibit 5 - Austin Order, # 6 Exhibit 6 - FDNY Validity Report, # 7 Exhibit 7 - Baltimore Agreement, # 8 Exhibit 8 - RIDOC Agreement, # 9 Exhibit 9 - Lubbock Decree, # 10 Exhibit 10 - Austin Decree, # 11 Exhibit 11 - MDOC Agreement (Part 1), # 12 Exhibit 11 - MDOC Agreement (Part II))(GIVEN, EMILY) (Entered: 01/15/2025)

1 Exhibit 1 - Scherbaum Declaration

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2 Exhibit 2 - Goldstein Declaration (redacted

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3 Exhibit 3 - MDSP Order

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4 Exhibit 4 - Lubbock Order

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5 Exhibit 5 - Austin Order

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6 Exhibit 6 - FDNY Validity Report

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7 Exhibit 7 - Baltimore Agreement

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8 Exhibit 8 - RIDOC Agreement

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9 Exhibit 9 - Lubbock Decree

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10 Exhibit 10 - Austin Decree

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11 Exhibit 11 - MDOC Agreement (Part 1)

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12 Exhibit 11 - MDOC Agreement (Part II)

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Jan. 15, 2025

Jan. 15, 2025

RECAP
21

MOTION to Seal [If the party filing this motion is not the party claiming confidentiality, the party claiming confidentiality must file a response within 14 days that includes the materials required by L.R. 5.4(c)(3).] by UNITED STATES OF AMERICA. Response to Motion due by 1/29/2025 (Attachments: # 1 Text of Proposed Order)(GIVEN, EMILY) (Entered: 01/15/2025)

1 Text of Proposed Order

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Jan. 15, 2025

Jan. 15, 2025

RECAP
22

SEALED UNREDACTED DOCUMENTS Brief Regarding Applicability of Ricci v. DeStefano to Motion for Provisional Approval and Entry of Consent Decree (public version filed at 20) (highlighted) filed by Plaintiff UNITED STATES OF AMERICA, Defendant CITY OF DURHAM, NORTH CAROLINA re 20 Brief,, 21 Motion to Seal,. (Attachments: # 1 Exhibit 1 - Scherbaum Declaration, # 2 Exhibit 2 - Goldstein Declaration (highlighted), # 3 Exhibit 3 - MDSP Order, # 4 Exhibit 4 - Lubbock Order, # 5 Exhibit 5 - Austin Order, # 6 Exhibit 6 - FDNY Validity Report, # 7 Exhibit 7 - Baltimore Agreement, # 8 Exhibit 8 - RIDOC Agreement, # 9 Exhibit 9 - Lubbock Decree, # 10 Exhibit 10 - Austin Decree, # 11 Exhibit 11 - MDOC Agreement (Part 1), # 12 Exhibit 11 - MDOC Agreement (Part 2))(GIVEN, EMILY) (Entered: 01/15/2025)

Jan. 15, 2025

Jan. 15, 2025

PACER
23

Suggestion of Subsequently Decided Authority re 20 Brief,, by Plaintiff UNITED STATES OF AMERICA. (Attachments: # 1 Exhibit Jan. 16, 2025 Order in U.S. v. Cobb County, Ga.)(RICH, ROBERT) (Entered: 01/16/2025)

1 Exhibit Jan. 16, 2025 Order in U.S. v. Cobb County, Ga.

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Jan. 16, 2025

Jan. 16, 2025

RECAP
24

NOTICE of Special Appearance by attorney CAMERON THOMAS NORRIS on behalf of Amicus AMERICAN ALLIANCE FOR EQUAL RIGHTS ( Filing fee $ 25 receipt number ANCMDC-3999444.) (NORRIS, CAMERON) (Entered: 01/17/2025)

Jan. 17, 2025

Jan. 17, 2025

RECAP
25

NOTICE of Special Appearance by attorney PAUL RICKARD DRAPER on behalf of Amicus AMERICAN ALLIANCE FOR EQUAL RIGHTS ( Filing fee $ 25 receipt number ANCMDC-3999465.) (DRAPER, PAUL) (Entered: 01/17/2025)

Jan. 17, 2025

Jan. 17, 2025

RECAP
26

L.R. 5.5 REPORT-Joint for the Filing of Sealed Documents by Plaintiff UNITED STATES OF AMERICA. (GIVEN, EMILY) Modified on 1/28/2025 to correct event. (ae) (Entered: 01/27/2025)

Jan. 27, 2025

Jan. 27, 2025

RECAP

Motion Referred to MAGISTRATE JUDGE JOI ELIZABETH PEAKE RE: 26 L.R. 5.5 Report-Joint filed by all parties. (ae)

Jan. 28, 2025

Jan. 28, 2025

PACER

Motion Submitted to JUDGE THOMAS D. SCHROEDER: 21 MOTION to Seal. (ae)

Jan. 30, 2025

Jan. 30, 2025

PACER
27

ORDER signed by MAG/JUDGE JOI ELIZABETH PEAKE on 01/30/2025, granting 26 Motion for L.R. 5.5 Report-Joint as approved as submitted. (at) (Entered: 01/30/2025)

Jan. 30, 2025

Jan. 30, 2025

RECAP
28

NOTICE of Voluntary Dismissal of case by Plaintiff UNITED STATES OF AMERICA (GIVEN, EMILY) (Entered: 02/25/2025)

Feb. 25, 2025

Feb. 25, 2025

RECAP

Case Details