September 2006 Volume 28 Number 4
Major League Baseball did not discriminate against retired Caucasian players
Major League Baseball did not discriminate against retired Caucasian players by giving health insurance and supplemental income to former Negro League players, a federal Court of Appeals has affirmed.
The appellate court ruled that retired Caucasian players had not shown they were discriminated against in violation of Title VII, for two reasons. First, although they had not received the same benefits as those provided to former Negro League players, they had not suffered an “adverse employment action,” because Major League Baseball had not engaged in an “employment action” at all when it provided insurance and supplemental income to Negro League players. Second, the Caucasian players were “not similarly situated in all material respects to former Negro League players” – not even those Negro League players who eventually played in the Major Leagues.
Alternatively, the appellate court ruled that Major League Baseball had “a legitimate, non-discriminatory and non-pretextual reason for awarding” benefits to African-American players and not to Caucasian players. Until Jackie Robinson broke the color barrier in 1947, the appellate court explained, African-Americans had been excluded from the Major Leagues, and thus were injured in a way Caucasians were not. Indeed, the appellate court said, “. . . Caucasians [were] the beneficiaries of the discriminatory policy” and “they had every opportunity to acquire eligibility for [Major League] benefits.”
As a result, the appellate court affirmed a summary judgment that had been granted to Major League Baseball by the District Court.
Moran v. Selig, 447 F.3d 748 , 2006 U.S.App.LEXIS 11464 (9th Cir. 2006 )