White Police Officer’s Reverse Discrimination And Retaliation Claims Fail

Michael Arendale, a white police officer employed by the Memphis Police Department, brought suit against the city under state and federal civil rights statutes alleging workplace discrimination and retaliation. The United States District Court granted summary judgment in the city's favor. On appeal, the 6th Circuit affirmed, holding that:  (1) Arendale failed to establish that his disciplinary suspension for insubordination towards his African-American supervisor violated his equal protection rights, even if the supervisor had never filed charges of discipline against any non-white officer, where there was no evidence that any minority officer had engaged in similarly-sanctionable conduct, but received a less severe sanction; and (2) the fact that Arendale was suspended for insubordination two months after he filed a charge of discrimination with the Equal Employment Opportunity Commission (EEOC) was insufficient, by itself, to support the causal connection element for a retaliation claim.

Arendale v. City of Memphis

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The 6th Circuit Court of Appeals’ jurisdiction includes Michigan, Ohio, Kentucky and Tennessee.