Wiggs v. City of Philadelphia, 2014 U.S. Dist. LEXIS 24978 (U.S.D.C. East. Dist. Pa., 2/14)

Claims for alleged failure to train and supervisory liability relating to police psychological evaluation dismissed.

The plaintiff, an African American woman, was 50 years old when she applied for a position with the Police Department. The City has responsibility for testing, hiring, training and supervising employees of the Police Department. As part of the job application process, the plaintiff was required to undergo a psychological evaluation conducted by a doctor, a white woman. The defendants conducted the psychological evaluation in a manner that was contrary to the standards prescribed by the Uniform Guidelines on Employee Selection Procedures. The plaintiff was notified by letter that her application for employment as a Police Officer Recruit had been terminated as a result of her psychological evaluation. The plaintiff had undergone psychological evaluations conducted by the City on two prior occasions, and both evaluations were satisfactory. The plaintiff brought claims against the City for failure to train and supervise and for supervisory liability pursuant to 42 U.S.C. § 1983. The City filed a motion to dismiss. The court concluded that the plaintiff failed to state facially plausible Section 1983 claims against the City for violating her rights under the failure to train or supervisory liability theories. The court reasoned that the plaintiff’s complaint fails to allege any facts that support its legal conclusion that the City was deliberately indifferent to the need for adequate training and supervision relating to the administration of psychological evaluations or its need to monitor the individuals who administer the psychological evaluations.

Case Law Alerts, 2nd Quarter, April 2014