President Obama signed an Executive Order that prohibits discrimination based on sexual orientation and gender identity in federal hiring and for federal contractors and subcontractors.  The Order requires that the US Department of Labor issues regulations to implement the order within 90 days. This Order takes effect immediately as to the hiring and employment provisions affecting over 2.5 million Federal employees. Contracts entered into on or after the regulations are promulgated by the Department of Labor must comply with the Order. Federal contractors will be required to maintain and/or amend hiring and employment policies against discrimination based on sexual orientation and gender identity.

Currently, there is no federal law that prohibits discrimination based on sexual orientation and gender identity that applies to all employers with 15 or more employees. The Employment Non-Discrimination Act (“ENDA”) would extend existing federal law protections to LGBT employees and was approved by the Senate, but has stalled in the House of Representatives. 21 states (NH and MA included) and the District of Columbia have passed laws prohibiting employment discrimination based on sexual orientation and 18 states (MA included) also prohibit discrimination based on gender identity.

This blog was originally posted in the Employment Law Business Guide on July 22. Click here to read the original entry. 

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Categories: Discrimination | Diversity

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A California District Court has ruled in favor of a Muslim employee of Abercrombie & Fitch who claimed Abercrombie failed to accommodate her religious beliefs when it banned her from wearing her hijab. The plaintiff, 19-year-old Umme-Hani Khan, wears a traditional Muslim head scarf, called a hijab, in observation of her religion. She wore the garment to her hiring interview, as well as throughout her four month employment period for the company’s Hollister store in San Mateo, California, where she was an “impact associate” working primarily in the stockroom.  Khan’s local supervisors permitted her to wear the hijab so long as it matched the company’s colors. However, when a visiting district manager saw the hijab, he informed the local supervisors that Khan was not in compliance with the company’s “look policy.” She was then asked if she could remove the garment while at work and was told that if she did not, she would be taken off schedule. Khan denied the request, stating it was part of her religious observance. She was thereafter terminated.

The Equal Employment Opportunity Commission attempted to resolve the dispute with Abercrombie, but rejected the company’s affirmative defense of undue hardship and brought suit alleging discrimination on the basis of religion in violation of Title VII of the Civil Rights Act of 1964. The act prohibits discrimination based on religion and requires employers to accommodate religious beliefs or practices of employees unless doing so would impose an undue hardship.

In defense, Abercrombie claimed its grooming policy prohibits employees from garnishing head-wear and requires them to project a beach-inspired image, which is essential to the company’s business model. Thus, it claims it could not reasonably accommodate Khan without undue hardship.

Abercrombie further claimed in federal court that the EEOC did not make a good faith attempt to resolve the matter, which is required before it can file a suit. The district court judge held that while there is no standard for reviewing whether the EEOC made a good faith attempt to settle the dispute, extensive negotiations between the parties provided sufficient evidence of an attempt to settle and therefore supported the filing of the suit in federal court.

The judge noted that despite Abercrombie’s claim that an accommodation for Khan would constitute an undue hardship, it provided no evidence that Khan’s attire affected sales or disturbed customers, nor any data whatsoever tending to show that the company’s “look policy” affected sales. The judge concluded that Abercrombie could have made an accommodation for Khan without undue hardship.

Abercrombie next argued that its employees were “living advertisements” for the company and therefore constituted commercial speech that was entitled to protection by the First Amendment. The judge dismissed this allegation, holding that employees who are hired to fold and stock clothing cannot be considered “living advertisements” and therefore their attire is not protected as commercial speech.

This isn’t the first time Abercrombie has found itself defending its “look policy.” In fact, it is the third time a district court has ruled against the company and its defense of undue hardship in cases involving Muslim employees or applicants wearing a hijab.

This case, and other rulings against Abercrombie, demonstrate to employers the importance of understanding what reasonable accommodations must be made for an employee or applicant’s religion, as well as what constitutes an undue hardship. Clearly, Abercrombie has been unsuccessful in asserting that any change to its “look policy” and business model would be an undue hardship.

For further information on what constitutes a reasonable accommodation and undue hardship, click here

This blog was originally posted on October 17, 2013 by Jampol Zimet LLC. Click here to read the original entry. 

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This month, a complaint was filed against Fidelity National Title Group, Inc. in Los Angeles Superior Court by one of its former employees alleging discrimination based on gender, pregnancy, and a medical condition, as well as retaliation, harassment, and intentional infliction of emotional distress.

In Stepp v. Fidelity National Title Group, the former employee, Jessica Stepp, a female attorney, was hired by the company when she was five (5) months pregnant. She claims that throughout her pregnancy, her supervisor and coworkers made disapproving remarks regarding her pregnancy and of her choice to have children, for example, asking when she would be getting her tubes tied. When she returned to work after delivering her child, she claims her supervisor was unaccommodating. She requested a windowless office to allow her to pump breast milk, which her supervisor denied and told her to “figure things out.” Her supervisor also denied her a lock for her office door, and instead required her to hang a “do not disturb” sign on her door’s exterior announcing that she was in the midst of pumping. After a worker accidentally walked in on her with her top off, she installed a lock herself.

Throughout her employment, Stepp further claims her supervisor refused to lighten her case load even when medically necessary. Following the birth of her child, Stepp became pregnant again, but miscarried resulting in an emergency medical leave. During this period, motions were due to be filed in court. However, her supervisor refused to assign them to another attorney stating Stepp had to figure out a way to get them done herself.

The complaint further alleges that not only did she receive a heavy case load, but other female attorneys in the office did as well, a problem not suffered by any of her male coworkers. Her workloads forced her to work seventeen (17) hours per day, and she was forced to take on the additional duties of a paralegal after one quit. Of the other women heavily burdened (all of whom had children), one quit her job because she felt she could be liable for malpractice as a result of her unmanageable caseload.

Finally, the complaint claims Stepp was fired as a result of inadequate performance, despite all other male employees being given a probation period prior to termination.

This case underlines the importance of employers treating their employees equally to avoid the filing of lawsuits alleging discrimination. As we found out several weeks ago in Inconsistent Treatment of Employees Could Land You in Hot Water, disparate treatment of employees is sufficient to support a claim for discrimination and is an issue properly determined by the trier of fact. Here, it appears Stepp has met her burden in alleging disparate treatment among female and male coworkers such that her case may proceed. It is therefore important for employers to ensure they, as well as supervisors, follow clear employment protocols and are trained to avoid situations that may give rise to liability.

This blog was posted on August 27 on Jampol Zimet’s Insurance Defense Blog. Click here to see the original post. 

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Categories: Discrimination | Law Suit

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Too Good Looking to Work Here

Posted on July 26, 2013 04:59 by Scott F. Gibson

Imagine the following scenario.  Your boss calls you in to the office, tells you that you have been a stellar employee, and then fires you because “you’re so darn good looking that I’m afraid I’ll have an affair with you.”

Your boss clearly failed to read the memo on “Best Employment Practices:  Staff Motivation.” But is your termination legal?
According to the recent decision of the Iowa Supreme Court, your boss can legally terminate you because he (or she) finds you irresistible, even if you have not engaged in flirtatious or inappropriate behavior. The decision to terminate was not based on gender (which would be discriminatory and illegal), but instead on your boss’s feelings (which are not prohibited by law, no matter how irresponsible the feelings might be).
The case involved dentist James Knight who fired his assistant Melissa Nelson, who he acknowledged had been an exemplary employee for 10 years.  Dr. Knight had developed an attraction to Ms. Nelson, and he (and, perhaps more importantly, his wife) believed that his attraction had become a threat to his marriage. 
The Court’s latest decision reinstated the result of its opinion reached in December 2012, which the Court withdrew after the decision received nationwide publicity and criticism.  

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I do not follow celebrity news gossip, but even I heard that Paula Deen was recently deposed and some are not happy about her testimony.  CNN put the transcript on its website.  The CNN link may not last, but federal court filings do.  If someday the CNN link fails, the deposition was publicly filed as document 197-1 in case 12-cv-00139.  The case may be accessed via PACER for the Southern District of Georgia.  To be absolutely clear, I have not read the 149 page transcript or any of the filings in this case.

If I have not read the deposition, why am I posting about it?  It is certainly not to add my voice to the celebrity gossip firestorm.  Instead, the point of this post is to discuss a few issues that can arise when representing public figure clients.  Paula Deen’s current case prominently highlights a few them.  When a request to depose your public figure client arrives, what are some of your options to help avoid the firestorm currently surrounding Paula Deen?

Seek a Protective Order

NRCP 26(c) authorizes a court to issue a protective order, in certain circumstances, to govern discovery.  If a litigant is a well-known public figure, one litigation strategy may be to leverage that profile against her to force a favorable resolution.  I am not saying this occurred to Paula Deen.  If you are defending the public figure, it may be prudent to seek a protective order before discovery begins.  NRCP 26(c) permits “for good cause shown, the court in which the action is pending may make any order which justice requires to protect a party or person from annoyance, embarrassment, oppression, or undue burden or expense.”

But wait, court documents are public records so discovery materials are presumptively public!  Probably not.  In Seattle Times Co. v. Rhinehart, 467 U.S. 20 (1984) a religious organization sued a newspaper.  The organization was concerned the paper would publish information it learned in discovery and sought a protective order.  The newspaper appealed and argued the order violated its First Amendment rights.  The Supreme Court of the United States disagreed and, in short, stated there may be constitutionally permissible reasons for a court to restrain the use of information gathered via the discovery process.  The debate about this topic did not end in 1984.  The legal community continues debating the extent to which information gathered via court-permitted discovery is or is not public.   See Richard L. Marcus, A Modest Proposal: Recognizing (At Last) that the Federal Rules No Not Declare That Discovery is Presumptively Public, 81 Chi.-Kent L. Rev. 33 (2006).

Where representing a public figure, a protective order is one way to seek to focus the case and avoid a situation like Paula Deen is enduring.

Object to Apex Depositions

The Paula Deen lawsuit reportedly involved a restaurant in which she had some involvement.  I do not know what level of involvement Paula Deen had in the daily operations of the restaurant in her lawsuit, but, for an example, consider Wolfgang Puck.  Here in Las Vegas, it sometimes feels like Wolfgang Puck affiliated restaurants are nearly as ubiquitous as Starbucks, but typically with far better food.  Obviously he cannot be involved in the daily operations of each of these restaurants and his other businesses.  But if a customer files a run of the mill personal injury lawsuit against the restaurant, what is to stop the customer from then deposing Wolfgang Puck himself?

The response is to move for a protective order and rely upon the apex doctrine.  Why?

Under the “apex doctrine,” courts sometimes grant protective orders barring the depositions of high-level corporate officers or managers who are unlikely to have personal knowledge of the facts sought by the deposing party. If a deponent is a high-level corporate officer who certifies that he or she has no personal knowledge of the facts, the court may grant a protective order requiring the deposing party to first seek discovery through less intrusive methods, e.g., from lower level employees who are more likely to have direct knowledge.

6-26 Moore’s Federal Practice – Civil § 26.105.  The concept has been discussed locally in a case that resulted in a blog post.  Luangisa v. Interface Operations, 2011 U.S. Dist. LEXIS 139700, 2011 WL 6029880 (D. Nev. 2011).  Remember, it is difficult to qualify for an apex exception to deposition.

I do not know if Paula Deen would have qualified for the apex exception, but it is another tool to help control discovery for cases involving public figures.

At the Deposition: Do What You Can Within the Rules to Defend Your Client
What can you do to defend your public figure client if she is deposed?  First, keep your head.  I can appreciate how representing a public figure might create certain expectations and pressure. I can only urge you not to jettison everything you learned and practiced leading up to this moment, walk into a deposition and be a baddie.  This blog has already discussed what happens when good lawyers act out of character and the ramifications of those actions.  Public figure client or not, the rules still apply.

Second, prepare your client.  If the client is a public figure that is probably easier said than done.  I can only speculate that the lawyers for Lil Wayne and Lady Gaga did not prep them to act as they once did.  The public figure deponent must be ready, like any other client, to present their testimony in the best manner possible.

Third, although you as the defending attorney are a potted plant and there is little you can do, control what you can.  Assert appropriate objections because, if your client is well prepared, she will remember an objection means there may be something wrong about the question which must be addressed.  Take breaks when needed.  It does not look good, especially in a video recorded deposition, to take a break in the middle of key testimony, or multiple breaks in the space of a few questions, but if your client is melting down its all you can do.  Get the client outside the room, calm her down and try to restore sanity to the situation. Be wary however, as in some jurisdictions there is no attorney-client privilege during deposition breaks.

At the Deposition: Terminate and Move for a Protective Order, if Necessary

If everything else fails and the deposition questioning is simply out of line and control, consider terminating and moving for a protective order. I generally consider this the nuclear option but, as sadly documented by various posts on this blog, sometimes it cannot be avoided.

At any time during the taking of the deposition, on motion of a party or of the deponent and upon a showing that the examination is being conducted in bad faith or in such manner as unreasonably to annoy, embarrass, or oppress the deponent or party, the court in which the action is pending or the court in the district where the deposition is being taken may order the officer conducting the examination to cease forthwith from taking the deposition, or may limit the scope and manner of the taking of the deposition as provided in Rule 26(c). If the order made terminates the examination, it shall be resumed thereafter only upon the order of the court in which the action is pending. Upon demand of the objecting party or deponent, the taking of the deposition shall be suspended for the time necessary to make a motion for an order.

NRCP 37(d)(3).  The converse is also true for the defending attorney.  “If the court or discovery commissioner finds that any impediment, delay, or other conduct has frustrated the fair examination of the deponent, it may impose upon the persons responsible an appropriate sanction, including the reasonable costs and attorney’s fees incurred by any parties as a result thereof.”  NRCP 37(d)(2).

As you contemplate whether to terminate your public figure client’s deposition, consider a few factors.  The courts really do seem to consider termination the nuclear option.  If you terminate a deposition, you had better have a rock solid reason for it or you will probably be paying for the continued deposition.  Also, if you terminate your public figure client’s deposition, it is your duty to act as quickly as possible to file the motion for protective order.  The courts likely understand there is a slight delay as you gather a transcript, but order a rush copy.  If you do not act promptly, the courts may consider this a sign of bad faith.  Finally, do you need to conduct a separate “meet and confer” conference before filing a discovery motion?  There is no bright-line rule, but use common sense, assuming any remains if the deposition is so bad that you are terminating it.  In such a situation, I typically find the reason counsel cannot agree is already in the transcript.  A separate “meet and confer” would serve no purpose.  Having said that, it may be beneficial to go the extra mile and initiate a separate “meet and confer” in the days after the deposition as you prepare the motion for protective order.  It might be difficult to conduct but a day or two cooling period could facilitate at least a rational discussion of the situation and how best to proceed.  I would not hold my breath, but it is possible.

The Deposing Attorney: Don’t Go Crazy

If you are deposing a public figure, the same “don’t go crazy” rule applies to you too.  Also remember there are limitations about what an attorney can and cannot say publicly about his client’s case.  There was once a local kerfuffle about those limitations.  Gentile v. State Bar of Nevada, 501 U.S. 1030 (1991).

At the end of the day, public figure depositions can raise complications.  I can only encourage the lawyers involved to recognize these potential complications early and try to stay ahead of them.

This article was originally posted on June 28 on Michael P. Lowry’s “Compelling Discovery” blog. Click here to read the original post. 

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Categories: Discrimination | Law Suit | Media

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Last month, the Equal Employment Opportunity Commission (EEOC) settled its first lawsuit under the Genetic Information Nondiscrimination Act (GINA). GINA was enacted in 2008 and took effect in 2009. It prohibits an employer from using genetic information to make employment decisions, including decisions related to the hiring, firing, promotion, pay, job assignments, training, and benefits of its employees.

The suit arose when Fabricut, a large fabric distributor, asked a temporary employee applying for a full time position to disclose her family medical history in a post-job-offer physical exam. At her physical, the employee was required to complete a questionnaire, which included questions related to her family history of specific medical disorders, including heart disease, hypertension, cancer, tuberculosis, diabetes, arthritis, and “mental disorders.”

The EEOC alleged in the suit that because the questionnaire requested the employee’s family medical history, a GINA violation had occurred. The suit was settled for $50,000 and Fabricut agreed to take actions designed to prevent future discrimination. The EEOC stated that once Fabricut was aware of the violations, it took action to remedy the situation and worked with the EEOC to reach a settlement.

David Lopez, general counsel of the EEOC stated, “Employers needs to be aware that GINA prohibits requesting family medical history. When illegal questions are required as part of the hiring process, the EEOC will be vigilant to ensure that no one be denied a job on a prohibited basis.” EEOC Regional Attorney Barbara Seely further noted that despite the fact that GINA has been law since 2009, “many employers still do not understand that requesting family medical history, even though a contract medical examiner violates this law.” The EEOC has stated that addressing emerging issues in the employment field, such as genetic discrimination, is one of the six national priorities identified in EEOC’s Strategic Enforcement Plan for 2013-2016.

The fact that GINA is a relatively new law applying to employers means that employers need to be proactive in educating management and employees regarding the law’s prohibitions to ensure that violations aren’t inadvertently made. The case of Fabricut serves as a reminder to employers who are unaware of GINA’s implications that is important to stay concurrent with laws that apply to an employer’s conduct to ensure that no violations, whether intentional or not, are made.

This blog was originally posted on Jampol Zimet's Insurance Defense Blog on June 20. Click here to see the original post. 

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Categories: Discrimination | Health Care Law

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The underlying premise of the U.S. Supreme Court’s precedent in Grutter v. Bollinger is that students benefit from being in a racially diverse educational environment.  As the justices prepare to reconsider the issue of affirmative action in higher education, new research has emerged which examines Grutter’s premise.  The study, “Does Race Matter in Educational Diversity? A Legal and Empirical Analysis,” concludes that law students actually do benefit from racial diversity on campus and that law schools should work to maintain diverse classes.  University of North Carolina School of Law professor Charles Daye conducted the research along with University of North Carolina psychology professor A.T. Panter; University of California, Los Angeles sociology professor Walter Allen; and University of North Carolina at Greensboro professor emeritus Linda Wightman.  Their findings are based on data collected from law schools over a decade. The team surveyed approximately 6,500 incoming students at 50 law schools about their own backgrounds, expectations and experiences. They also conducted periodic focus groups consisting of approximately 200 students throughout their three years in law school.  

The researchers set out to answer two basic questions: Does race make a difference to what students bring to law school? If so, are any differences reflected in the quality of education students receive?  The data shows, resoundingly, that students of different races do come to law school with differences in experience and perception, Daye said.  Perhaps more important, those differences translated into a richer educational experience overall, according to the surveyed students.  "Diversity matters in the way students conduct conversations in class, how they interpret cases, in the way they interact in social settings and with their professors," Daye said.  Critics contend that the study authors used shoddy science to reach predetermined conclusions by relying on self-reporting of law students and assert that the study only demonstrates that students think that diversity helps their understanding of the law.
Does race matter in educational diversity and, if so, how do you measure or quantify the difference that it makes?  Does race make a difference to what students bring to higher education?  If so, are any differences reflected in the quality of education students receive?

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This fall, the United States Supreme Court will reconsider the issue of affirmative action in higher education for the first time since its 2003 decision in Grutter v. Bollinger.  In Grutter the Court held that, “The Equal Protection Clause does not prohibit the [University of Michigan] Law School’s narrowly tailored use of race in admissions decisions to further a compelling interest in obtaining the educational benefits that flow from a diverse student body.”  The Court will consider the appeal of Abigail Fisher, a white student, who alleges she was denied admission to the University of Texas because of the color of her skin.  At issue in the Fisher case is whether the Court’s decisions interpreting the Equal Protection Clause of the Fourteenth Amendment, including Grutter, permit the University of Texas at Austin’s use of race in undergraduate admissions decisions. 

The Supreme Court’s decision stands to have great impact nationally.  Numerous amicus briefs have been filed in support of both litigants.  Of note, the University of California (UC) president and chancellors, the state of California, the California Institute of Technology and a group of student organization at UC campuses are among at least 69 organizations that have filed amicus briefs in support of the University of Texas at Austin.  California is one of a few states that have already prohibited affirmative action in college admissions following the passage of Proposition 209 in 1996.  In its amicus brief, UC attorneys argued that the university system’s experience after Prop. 209 “sheds important light on the practical, real-world obstacles faced by universities seeking to obtain the educational benefits that flow from a diverse student body.”  Similarly, the brief filed on behalf of the state of California by Attorney General Kamala Harris observed that if California, a large and diverse state, could not achieve an acceptable level of diversity in its public universities in the absence of race-conscious admissions policies, other states with more homogeneous populations would struggle to an even greater extent.

Despite several initiatives enacted after the passage of the proposition, UC has not been able to reverse the decline in minority admission and enrollment since 1998, when the law went into effect.  Between 1995 and 2009, African Americans consistently represented between 7 and 8 percent of new high school graduates in California.  In 1995, African Americans made up 7.3 percent of admitted freshmen at UC Berkeley, but by 1998, that figure had dropped to 3.2 percent. In 2010 and 2011, it was 3.9 percent. UCLA saw similar results.

Is diversity a sufficiently compelling reason to use race in admissions decisions?  Is there a compelling interest in obtaining educational benefits from a diverse student body?  Could a reversal of the Court’s decision in Grutter result in less diverse student bodies at public colleges and universities as has been experienced in California?


Alison Y. Ashe-Card

Womble Carlyle Sandridge & Rice, LLC

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On Monday, our United States Supreme Court promised plenty of work for our brothers and sisters on the nation’s border states practicing governmental liability law.  In Arizona v. United States, 567 U.S. ___ (2012), among other rulings, the 5-3 (9-0 on Section 2(B)) Court upheld Arizona’s controversial Show Me Your Papers provision, which requires local law enforcement to check the immigration status of people they stop for another reason.

Rejecting the United States’ position that federal law pre-empts the Arizona statute in this effect, the Majority broadly reasoned that this particular law complimented, rather than stood as an encroachment, into the federal immigration power.  The Court also reasoned that as a facial challenge to a pre-effect law, it had before it neither a factual record, nor the “benefit of a definitive interpretation from the state courts” upon which to address any Fourth Amendment or other preemption concerns.

The law requires state officers to make a “reasonable attemptto determine the immigration status” of any person they stop, detain, or arrest on some other legitimate basis if “reasonable suspicion exists that the person is an alien and is unlawfully present in the United States.”  Pretermitting the obvious – that every stop will take longer once reasonable suspicion kicks in, the Court also chose not to deal with 2(B)’s vagueness, nor its obvious invitation to practice racial profiling.  This comes as no surprise, given the Court’s getting the Solicitor General at Oral Argument to concede that, at least at this stage, the case does not involve a racial profiling element.

The Court has turned loose to the lawyers and the courts the responsibility to create this definitive interpretation of how this law impacts the Fourth Amendment and other rights of United States citizens.  Arizona will see plenty of litigation over the certain-to-be future interplay at the in section of 2(B) and the Fourth Amendment.

Somewhat lost in the shuffle, is the Obama Administration’s having cancelled some agreements allowing Arizona Police Departments to enforce federal immigration laws. The Administration has set up a hot-line and email address for the public to report civil rights concerns.  It is unclear what impact this will have on the overall landscape.  It seems unlikely the Feds would pull such agreements nation-wide.


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This Day In History: June 13th

Posted on June 14, 2012 04:03 by Alison Y. Ashe-Card

On this day in 1967, President Lyndon B. Johnson nominated Thurgood Marshall to fill the seat of retiring U.S Supreme Court Associate Justice Tom Clark, saying that this was "the right thing to do, the right time to do it, the right man and the right place."  The Senate confirmed his nomination on August 30th by a vote of 69-11.  Upon his swearing in, Marshall became the 96th justice and the first African-American to sit on the nation’s highest court.  Only one other African-American, Clarence Thomas who succeeded Marshall, has served as one of the Court’s 112 justices.

Marshall, a Baltimore native, graduated from Lincoln University cum laude in 1930 and from Howard Law School in 1939 at the top of his class.  Marshall wanted to apply to his hometown law school, the University Of Maryland School Of Law, but the dean said he would not be accepted because of the school's segregation policy.  He practiced law privately in Baltimore before joining the NAACP as assistant counsel in 1936.  As the NAACP’s chief counsel from 1938 to 1961, Marshall, argued 32 cases before the high tribunal, repeatedly challenging racial segregation, most notably in public education. He won 29 of those cases, including a historic victory in 1954’s Brown v. Board of Education decision when the court, reversing itself, unanimously found that segregated schools violated the equal protection clause of the 14th Amendment.

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