Stagi v. AMTRAK

Stagi v. AMTRAK

Opinion

 [*134]  OPINION OF THE COURT

RENDELL, Circuit Judge.

Plaintiffs Sharyn Stagi and Winifred Ladd brought a class action against the National Railroad Passenger Corporation ("Amtrak"), asserting that a company policy requiring all union employees to have one year of service in their current position before they could be considered for promotion has a disparate impact on female union employees  [**2] in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e, and the Equal Protection component of the Due Process Clause of the Fifth Amendment. The District Court, presented with motions for class certification and for summary judgment, granted summary judgment in favor of Amtrak, finding that "the plaintiffs' evidence of disparate impact lack[ed] both statistical and practical significance," thus concluding that "the plaintiffs have failed to make out a prima facie case of discrimination under Title VII." Stagi v. Nat'l R.R. Passenger Corp., Civ. No. 03-5702, 2009 U.S. Dist. LEXIS 71207, 2009 WL 2461892, at *1 (E.D. Pa. Aug. 12, 2009) (Stagi II).

Although it is a close call, we will reverse and remand for further proceedings consistent with this opinion.

At issue in this case is Amtrak's policy referred to as the "one-year blocking rule." Under that rule, a union member must be in her current union position for at least one year in order to be eligible for promotion into a management position. The policy states, "[a]n agreement covered employee may not apply for a posted non-agreement covered position unless he or she has been in his or her current union for one year." App. 299. ¹ The rule  [**3] has no  [*135]  exceptions. The rule was first promulgated on May 1, 1994 and was revised in September 2000, which revision was in force during the time period relevant for this case.

Plaintiffs Stagi and Ladd are long-time Amtrak employees who have been employed in both its union and management ranks during their careers. Stagi began her career at Amtrak in 1973 as a reservation and information clerk, and eventually worked her way up to various union positions until the early 1990s, when she was promoted to a management position. She was in a management position in  [**4] April 2002 when she was laid off as a result of a corporate-wide management restructuring effort. Ladd was promoted to management in 1986 and continued to be promoted through management until April 2002, when her job was similarly eliminated. Because they had previously worked in Amtrak's union ranks, they were both entitled to "bump down" into a union position based on their retained union seniority. In the year following their layoffs, both applied for management vacancies, some of which they had previously held or supervised. They were both blocked by the one-year rule from being considered for those positions. Stagi remains in her union position. Ladd was not able to return to management before 2004, when she left on long-term disability and retired with benefits inferior to those she would have enjoyed had she been permitted to access a management position.

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