Every example below is a fictionalized composite created for educational purposes. The employees, employers, and facts are invented and do not represent any real person, company, or case. These examples are general public information, not legal advice.
- Fictional employee
- K.B., delivery driver
- Fictional employer
- Clearfield Auto Group Company
- Location
- a city in the Northeast
- Illustrated statute
- Title VII of the Civil Rights Act of 1964
Illustrative charge narrative
I was employed by Clearfield Auto Group Company as a delivery driver in a city in the Northeast. I am a member of a protected class based on my skin color. During my employment I was disciplined more severely than coworkers outside my protected class for the same conduct, and I was passed over for a promotion that was given to a less qualified employee outside my protected class. When I raised concerns about unequal treatment, a supervisor dismissed them. I believe I was discriminated against because of my skin color, in violation of Title VII of the Civil Rights Act of 1964.
Teaching point
This charge is well pleaded because it identifies the protected trait, names specific adverse actions (discipline and a denied promotion), and pleads comparators, that is, similarly situated employees outside the protected class who were treated more favorably. Comparator evidence is often the backbone of a disparate treatment claim.