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Case Study

CASE:   EEOC v. Target 2006 U.S. App. Lexis 21483 7th Circuit

Facts of the Case:  

In early 2000, an African-American name James Daniel, Jr. applied for an Executive Team Leader position with Target.  He was given tests, which he passed placing him in a very high percentile of those who have been previously tested.  Unfortunately he was not hired, and was given the explanation of not meeting the requirements of the position. Daniels did not receive any feedback as to what requirement he was meeting in the interviewing process.  

Later three other African-American applicants, Kalisa White, Ralpheal Edgeston and Cherise Brown inquired about the same position involving contact with the Store Team Leader Matthew Armiger.  White sent her resume and called to schedule an interview, but was told by Armiger on several occasions he was busy.  She then enlisted the help of a friend who was Caucasian.  This friend sent her resume and acted as if she was “Sarah Brucker”, but used White’s correct phone number.   Her friend was able to contact Armiger and obtain an interview, while White called 15 minutes later and was told he was busy. Ralpheal Edegeston submitted her resume also and was unsuccessful in obtaining an interview.  Cherise Brown-Easley however was able to schedule a phone interview, but Armiger was not available during the scheduled time and did not contact Easley to reschedule. He also did not return repeated phone calls for rescheduling. It was in 2001 when White decided to file a case with the EEOC based on discrimination in the hiring process.  

After investigating the EEOC determined Target violated Title VII of the Civil Rights Act of 1964, particularly Section 709(c), by not keeping proper documentation nor retain records as required.   This issue was not resolved and required the EEOC to file a complaint in the lawsuit requesting a court hearing.

Under the two-and-one-half-year consent decree ending this nearly six-year old litigation (Civil Action No. 02-C-0146, filed in the U.S. District Court for the Eastern District of Wisconsin in Feb. 2002), Target agreed to pay a total of $510,000 to Kalisha White, Ralpheal Edgeston Brown, Cherise Brown Easley, and James Daniels, Jr. – African Americans who were denied jobs as assistant store managers in 2000 and 2001. As part of the decree, Target also agreed to revise its document retention policies; provide training to supervisors on employment discrimination and record-keeping; report on hiring decisions; and post a notice about the consent decree to employees in its District 110 stores and offices.