Angel Hernandez's Unlawful Discrimination Appeal Dismissed

The United States Court of Appeals for the Second Circuit dismissed plaintiff Angel Hernandez's discrimination lawsuit appeal against Major League Baseball, ruling in a summary order that despite a factual imbalance between white and minority crew chiefs, Hernandez's team failed to prove a statistically significant disparity in promotion rates, not to mention the case for discrimination or disparate treatment.

In 2021, a New York Southern District Court judge dismissed Hernandez's original discrimination case against MLB, opening up the door to appeal, when the court ruled that "the fact that no or very few minorities were promoted [is] 'statistically meaningless.'"

Related Post: Judge Dismisses Angel Hernandez's Discrimination Case (3/31/21).

That ruling itself followed MLB's allegation that there is "no evidence" of a diversity problem in baseball.

Related Post: MLB Argues No Evidence of Diversity Problem in Suit (6/8/20).

Regardless of where one stands on the diversity problem issue, the question is not whether such a problem exists, but whether unlawful discrimination or disparate treatment occurred in relation to the treatment of Mr. Hernandez, either by named decision-maker, then-Chief Baseball Officer Joe Torre, Peter Woodfork, or others in the Commissioner's Office.

And in sum, the court found that Hernandez failed to prove that element of the prima facie case, leading to the District Court's summary dismissal and, now, the Appeals Court's summary order of dismissal.

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Alternate Link: Hernandez loses unlawful discrimination appeal against MLB; case dismissed