The pattern-or-practice evidentiary framework is not appropriate for a suit against individual state officials in civil rights actions for intentional discrimination, the U.S. Court of Appeals for the Second Circuit ruled on July 11.
Addressing an issue of first impression, the circuit held that the statistical framework, usually applied in Title VII actions to make an initial showing that an entity engaged in discrimination, may not be applied when suing individuals on an Equal Protection theory under 42 U.S.C. §1983.
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