Williams v. Consolidated City of Jacksonville, Case Study Example

Abstract

This work in writing examines the case of Williams v. Consolidated City of Jacksonville, 341 F.Ed 1261 (11th Cir. 2003) and relates the background to the case as well as the facts of the case and the decision rendered by the court in this particular civil rights complaint.

Background

Chief Alfred, a black man was appointed on November 1, 1995, by Jacksonville Mayor to his position as director and chief of the Jacksonville, Florida fire department having been recruited from Washington D.C., where he had previously held the position of Fired Chief. The appointment of Chief Alfred based on a history of racism and nepotism in the Jacksonville, Florida fire department. The appointment of Chief Alfred was to negate the possibility that this would continue in the Jacksonville, Florida fire department, which incidentally had not Affirmative Action plan in place.[1]The chief of the rescue division, McCrone, proposed in 1999 that there be four new captain positions created in the rescue division and that they would be filled from an eligibility list generated in 1997. However, Chief Alfred decided that a new list should be generated.[2] It was alleged that Chief Alfred wanted a new list to ensure that the four white men were not promoted to the new positions. In the case of Williams v. Consolidated City of Jacksonville, 341 F.Ed 1261 (11th Cir. 2003) the Jacksonville Fire Chief Rayfield Alfred made a decision that he would not create four new roving captain positions in the Fire Captain Rescue Division of the Jacksonville Fire and Rescue Department as had been proposed by a subordinate official. Four white lieutenants in the fire department, specifically, the plaintiffs in this case, George A. Williams, Michael A Perryman, Michael B. Price, and Nolan A. Sauls, all of whom were passed over for promotion due to the decision of Alfred, filed the complaint in this case. The complaint was then filed in the form of a civil rights lawsuit against the defendants pursuant to §§ 1981 and 1983, Title VII, and the FCRA, alleging that in the absence of a valid affirmative action plan Chief Alfred’s decision not to create the roving captain positions amounted to unlawful race and gender discrimination in employment.[1]These four plaintiffs alleged that the decision of Chief Alfred “amounted to race and gender discrimination” and filed the complaint pursuant to 42 U.S.C. 1981 and 1983, Title VII of the Civil Rights Act of 1964, 42 U.S.C.§§ 2000e to 2000e-17, and the Florida Civil Rights Act of 1992 (FCRA), Fla. Stat. §§ 760.01-760.11, against the Consolidated City of Jacksonville and Chief Alfred in his individual and official capacities (collectively the defendants).[3]The plaintiffs asserted that but for their racial or gender identity, “Chief Alfred would have implemented or created the four Roving Captain Rescue Division positions at the time he was requested to do so, and at the time the need for those positions arose, before the eligibility list expired.”[4]

The Issue of Qualified Immunity and the Decision of the Appeals Court

The District Court denied the motion for summary judgment made by the defendant “based upon qualified immunity as to the claims against Chief Alfred in his individual capacity.”[5]The defendants then filed an interlocutory appeal and asserted that Chief Alfred is entitled to qualified immunity. The court found that Chief Alfred was indeed entitled to qualified immunity and the case was reversed and remanded to the district court with instructions to enter summary judgment in favor of Chief Alfred as to the claims brought against him in his individual capacity.”[6]

Discussion

Qualified immunity is stated to be of the nature that “offers complete protectionfor government officials sued in their individual capacities if their conduct ‘does not violate clearly established statutory or constitutions rights of which a reasonable person would have known.”[7]The principle of law upon which this is based is that in order for the public official to be granted qualified immunity that public official is responsible for showing proof that they acted within their discretionary authority. The burden is then placed upon the plaintiff to prove that qualified immunity is not appropriate and should not be granted. The plaintiffs failed to show such proof in this case.[8]

Bibliography

Vinyard v. Wilson 311 f.3d 1340, 1346 (11^th Cir.2002 cited in: VLEX: George A. Williams, Michael A. Perryman, Et Al., Plaintiffs-Appellees, v. Consolidated City of Jacksonville, Rayfield Alfred, Fire Chief, in His Individual and Official Capacities, Defendants-Appellants., 341 F.3d 1261 (11th Cir. 2003)

VLEX: George A. Williams, Michael A. Perryman, Et Al., Plaintiffs-Appellees, v. Consolidated City of Jacksonville, Rayfield Alfred, Fire Chief, in His Individual and Official Capacities, Defendants-Appellants., 341 F.3d 1261 (11th Cir. 2003)

[1]VLEX: George A. Williams, Michael A. Perryman, Et Al., Plaintiffs-Appellees, v. Consolidated City of Jacksonville, Rayfield Alfred, Fire Chief, in His Individual and Official Capacities, Defendants-Appellants., 341 F.3d 1261 (11th Cir. 2003)

[2]Ibid

[3]Ibid

[4]Ibid

[5]Ibid

[6] Ibid

[7]Vinyard v. Wilson 311 f.3d 1340, 1346 (11^th Cir.2002 cited in: VLEX: George A. Williams, Michael A. Perryman, Et Al., Plaintiffs-Appellees, v. Consolidated City of Jacksonville, Rayfield Alfred, Fire Chief, in His Individual and Official Capacities, Defendants-Appellants., 341 F.3d 1261 (11th Cir. 2003)

[8]VLEX: George A. Williams, Michael A. Perryman, Et Al., Plaintiffs-Appellees, v. Consolidated City of Jacksonville, Rayfield Alfred, Fire Chief, in His Individual and Official Capacities, Defendants-Appellants., 341 F.3d 1261 (11th Cir. 2003)