City's Public Safety Director Fell Under Personal Staff And Policymaking Exemptions To Title VII
In this
employment
discrimination action, Erby Conley claimed that the City of Erie, Pennsylvania
discriminated against him due to his race in violation of Title VII.
Specifically, Conley contended that the City eliminated his position of Public
Safety Director because he is African-American. The United States District Court
found that the City was
entitled to summary judgment, finding that Conley was not an "employee" under
Title VII, as he satisfied two exemptions to that definition. In addition to
being a member of the mayor's personal staff, he was also an appointee at the
policy making level.
Conley v. City of
Erie, Pa.