Blakney v. Medical Transportation Management, Inc.

Summary

The United States District Court for the District of Columbia granted Medical Transportation Management, Inc.’s motion to dismiss Count One of James Blakney’s complaint. The court held that the plaintiff failed to plausibly plead a disparate-impact claim because he relied on national and regional arrest and incarceration statistics without alleging disparities in MTM’s workforce or among qualified applicants affected by the challenged convictions policy.

Holdings

1. A plaintiff does not plausibly state a disparate-impact claim by relying solely on general national or regional arrest and incarceration statistics; the pleading must allege facts connecting the asserted disparity to the employer's qualified applicant or employee population and the challenged policy.

Questions Presented

1. Whether the complaint plausibly pleaded a disparate-impact claim based solely on national and regional arrest and incarceration statistics without allegations connecting those statistics to MTM's qualified applicant or employee population.

Disposition

dismissed