The following is a summary of the claim and preliminary statement filed in the UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION by attorney Robin Potter on behalf of the Chicago Teachers Union and three teachers.

PRELIMINARY STATEMENT 2. Defendants operate the Chicago Public School system (“CPS”), consisting of approximately 685 schools, servicing over 400,000 students in each of Chicago’s 77 neighborhoods. Approximately 90% of the students educated in CPS’s 578 non-charter schools are minorities, of which 42% are identified as African American. 3. CPS is currently divided into four (4) networks: Far South, South Side, Southwest Side and West Side. 4. The African American teaching force in CPS as a percentage of the overall teaching population has steadily declined, from 40.6% in 2000 to 29.6% in 2010. In 2011, African American teachers were approximately 28.7% of the tenured teaching population. Most of CPS’s African American teachers are employed in South and West side schools. 5. The drastic decline in African American teachers corresponds directly with Defendants’ intentional actions, policies and practices to phase out, close, combine or reconstitute purportedly poor performing schools.

6. From 2001 to 2009, Defendants BOE closed roughly 86 schools. From 2006 to present, 26 more schools have been subjected to reconstitution, commonly referred to as “turnaround,” a process in which all faculty and staff from a school are dismissed and replaced.

7. Defendants’ turnarounds have occurred exclusively in the South and West side neighborhoods, disproportionately affecting African American teaching and staff.

8. On or about February 22, 2012, Defendant BOE authorized the turnaround of 10 CPS schools, resulting in the termination of 347 tenured teachers, in addition to staff. African Americans constituted approximately 51% of the tenured teachers terminated, despite making up less than 30% of all CPS tenured teachers.

9. Defendants’ pattern and practice of intentionally targeting schools with high African American teaching and staff populations for turnaround constitutes disparate treatment and also has a disparate impact on African American tenured teachers and staff.