Gleanice Brown, Latrondra Moore, and Tamara Solomon, former detectives in the Crimes Against Children Unit of the Kansas City, Missouri, Police Department (KCPD), alleged discrimination based on race, age, and gender by their immediate supervisors and the KCPD. They claimed discrimination in disciplinary actions for various procedure and policy violations. The plaintiffs sued the Kansas City, Missouri Board of Police Commissioners (BOPC) under various federal civil rights laws. The BOPC moved for summary judgment against each Plaintiff. The Court granted the motions.
Facts Related To All Plaintiffs
In mid-September 2015, Major David Lindaman of the KCPD wrote to Deputy Chief Cheryl Rose regarding concerns from Jackson County Prosecutor Jean Peters Baker about the timeliness of cases being delivered by the KCPD’s Crimes Against Children (CAC) Unit. Baker’s concerns pointed to a broader issue within the unit. Concurrently, Baker communicated with Captain Todd Paulson and Major Lindaman about a phone call with Plaintiff Solomon, a detective in the CAC Unit. This interaction highlighted issues about the handling of cases and the performance of detectives within the unit.
These events triggered a series of internal reviews and investigations into the CAC Unit’s practices. The review process aimed to assess the performance and conduct of the unit members, including the plaintiffs, in managing their cases and adhering to departmental policies.
Additional Facts Related To Individual Plaintiffs
Facts Particularly Related to Moore and Brown’s Claims: Moore and Brown were assigned to administrative duty following a request from Jackson County Prosecutor Jean Peters Baker. On May 26, 2016, Baker asked Chief Forte to remove them from any position where they could serve as a police witness in criminal cases within Jackson County. In response, Chief Forte directed that Moore be removed from her field assignment and placed in an administrative role at East Patrol Division. Brown was also reassigned from her detective duties to an administrative role.
Facts Particularly Related to Solomon’s Claims: Tamara Solomon was assigned a disproportionately high number of cases during her time in the CAC Unit. Despite this, she received satisfactory performance evaluations until 2015. Yet her performance began to decline, and she was involved in several off-duty domestic violence incidents. In one incident, she was accused of failing to cooperate with the subsequent investigation. Following these incidents, Solomon’s employment with the KCPD was terminated.
Legal Analysis and Rulings
The court’s decision revolves around the application of the McDonnell Douglas burden-shifting framework, a legal standard used to assess claims of discrimination when direct evidence is absent. The plaintiffs, all former detectives in the KCPD’s Crimes Against Children Unit, alleged discrimination based on race, age, and gender, and retaliation in violation of various federal civil rights laws.
For Gleanice Brown, the court found that she could not establish a prima facie case of race, age, or sex discrimination. Key to this finding was the inability to show that she was meeting her employer’s legitimate expectations at the time of the alleged adverse employment actions. And the court noted that Brown could not identify any similarly situated Caucasian, male, or younger detectives who were treated more favorably under similar circumstances, which is crucial for establishing a discrimination claim.
Latrondra Moore’s case also failed to establish a prima facie case of discrimination. The court highlighted that she could not demonstrate that she was treated differently than similarly situated employees who were not members of her protected class. Like Brown, Moore’s inability to provide examples of similarly situated employees who were treated more favorably contributed to the court’s decision.
Tamara Solomon’s case was somewhat different, as it involved additional elements of off-duty conduct and performance issues. The court concluded that Solomon could not establish a prima facie case of race or sex discrimination. The court pointed out that Solomon’s termination resulted from a history of poor decision-making and unrelated to her complaints or protected characteristics.
In all three cases, the court addressed the retaliation issue. It noted that the plaintiffs failed to provide sufficient evidence linking their alleged protected activities (such as filing complaints or lawsuits) to the adverse employment actions they faced. The court emphasized the need for concrete evidence to support claims of retaliation, which was lacking in these cases.
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