托利弗诉伯明翰市案

Marlon Tolliver, a Black male sergeant employed at the Birmingham Police Department since 2009, applied for a promotion to lieutenant in 2022. Despite tying for third among eligible candidates, his application was placed on hold due to outstanding disciplinary matters. The Department's promotion guide disqualified candidates with 15 or more days of suspension within the preceding 24 months. Tolliver sued the City of Birmingham, alleging discrimination and retaliation. On June 11, 2025, Judge Anna M. Manasco of the U.S. District Court for the Northern District of Alabama granted the City's motion for summary judgment, dismissing all claims.

The court granted the City of Birmingham's motion for summary judgment on June 11, 2025, ruling in favor of the defendant and dismissing all of Tolliver's claims.

Whether the City of Birmingham unlawfully discriminated against Marlon Tolliver based on race or retaliated against him by denying his promotion to lieutenant due to his disciplinary history, and whether the promotional disqualification policy was applied in a discriminatory manner.

The case highlights ongoing legal debates surrounding promotional practices within law enforcement agencies and the application of disciplinary history in hiring decisions. It also underscores the challenges plaintiffs face in proving employment discrimination claims, particularly when objective criteria such as disciplinary records are used in promotional determinations. The ruling reinforces the discretion of public employers to enforce promotional eligibility standards based on disciplinary history.