Labor & Employment Law Daily Wrap Up, DISCRIMINATION—RACE—E.D. Mich.: Former Black officers at Detroit’s Renaissance Center advance class action alleging systematic bias, (Feb 11, 2026)

By Marjorie Johnson, J.D.

The officers’ sprawling complaint alleged that management condoned white officers’ racist slurs and mistreatment of Black visitors, engaged in discriminatory promotion practices, and retaliated against those who complained.

Former Black security officers at the Renaissance Center in Detroit, Michigan beat a motion to dismiss a class action lawsuit against several corporate and individual defendants alleging several state and federal claims, including that the defendants subjected them to a hostile work environment, engaged in a pattern and practice of systemic race discrimination, denied Black officers promotions and retaliated against them, and violated the state’s whistleblower law. Denying the defendants’ motion to dismiss or for a more definite statement, a federal district court in Michigan held that the Black officers made detailed allegations that “go well beyond labels and conclusions,” including specific allegations relating to white officers’ racially-charged remarks and several alleged violations of Black visitors’ constitutional rights, all of which they claimed were condoned by a GM official and other managers (Barnes v. G4S Secure Solutions (USA) Inc., No. 23-cv-12897 (E.D. Mich. Feb. 9, 2026)).

Corporate and individual defendants. Four former Black security officers filed this class-action lawsuit alleging racial discrimination and related claims connected to their prior employment as security personnel at the Renaissance Center. They sued four corporate defendants, which the court found they plausibly claimed were their joint employer. This included General Motors, LLC, whose global headquarters was in the Renaissance Center at all relevant times. They also sued a GM executive, the white security director, a Black supervisor, and several white officers.

Lengthy complaint. Their nearly 200-page complaint alleged claims under Michigan’s Elliott-Larsen Civil Rights Act (ELCRA), Section 1981, and 1983. Specifically, they claimed: (1) hostile work environment (HWE claim); (2) pattern and practice of systemic race discrimination (P&P claim); (3) race discrimination under a state-actor theory (pointing to a law that provides for the license and regulation of private security guards in Michigan); (4) failure to promote; and (5) retaliation. They also brought a claim under Michigan Whistleblowers’ Protection Act.

Not a “shot-gun pleading.” The court rejected the defendants’ contention that the HWE, P&P, failure to promote, and retaliation claims were impermissible “shotgun pleadings” because they conflated multiple claims and theories arising under different state and federal laws. While their latest complaint spanned almost 200 pages, and their HWE claims included 75 pages of supporting allegations, “the length is at least plausibly necessary given the unique nature of this case, specifically given the number of different plaintiffs and defendants at issue, as well as the years-long timeline over which the alleged discrimination occurred.”

Distinct HWE theories. The court also found that the Black officers plausibly alleged HWE claims under three primary theories: (1) white security officers’ racially-charged jokes, slurs, and related conduct; (2) white security officers’ discriminatory treatment of and constitutional violations against Black visitors; and (3) supervisors’ repeated failure to address and/or tacit endorsement of officers’ discriminatory conduct. Importantly, these theories all related to repeated conduct allegedly creating an HWE, rather than distinct acts of discrimination. And while some facts of their various claims might overlap, they explicitly alleged claims of discrete discrimination under separate counts specific to the type of discrimination at issue (non-promotion and retaliation).

Allegations related to Black visitors. To the extent their description of the treatment of Black visitors within their HWE claims included allegations specific to hiring practices and retaliation against those who reported discrimination, the court found it could be plausibly inferred that the repeated hiring and promotion of white employees with a history of racially-motivated constitutional violations contributed to the alleged HWE. While any specific racially-motivated retaliation or non-promotion against a Black officer would constitute a discrete act that could not be characterized as part of a continuing HWE, including such allegations in the HWE claims did not warrant dismissal of the claims.

Specificity. The Black officers also sufficiently alleged approximate and estimated timelines concerning much of the alleged discrimination. For example, they asserted that they were subjected to a pervasive HWE since 2017 and that certain officers complained to management about the alleged discrimination beginning in 2019. They also identified specific, approximate dates between 2019 and 2022 for when various racial jokes and other discriminatory conduct occurred. While many of the individual allegations generally referred to Black or similarly-situated officers rather than a specific plaintiff, the court held that such details could be clarified in discovery, and this lack of specificity did not warrant dismissal or a more definite statement.

Detailed allegations. The Black officers also made detailed allegations that “go well beyond labels and conclusions” and “certainly provide enough facts to raise a reasonable expectation that discovery will reveal evidence of illegal conduct.” For example, they alleged that white security officers continually made racially demeaning remarks during their employment and routinely violated Black visitors’ constitutional rights—behavior which was condoned by management. They also claimed the GM official and the security director failed to properly supervise officers and investigate complaints of racial discrimination and bias, and that the security director also retaliated against officers who engaged in protected activity. They also identified specific racially-charged comments and conduct allegedly committed by specific individual defendants.

The Black officers also alleged that the GM official, the security director, and the Black supervisor empowered security officers to use whatever force necessary to remove black visitors regardless of their constitutional rights and that one of the plaintiffs saw footage showing several white officers doing so. They also claimed several white officers intentionally provoked Black men to illicit a response, often resulting in wrongful detention or other constitutional violations, and that the white officers repeatedly detained, searched, and/or arrested black civilians based solely on race. The management-level defendants failed to conduct thorough use-of-force reviews.

Finally, they alleged that the specific individual defendants all ignored repeated complaints of racial discrimination, thereby condoning and creating a hostile work environment. They also claimed the management defendants knowingly hired officers who were previously fired for violating individuals’ constitutional rights, promoted white security officers over Black officers with more seniority and experience, and fired those who complained about discrimination.

Clarifications in discovery. “[W]hile it may be difficult to parse out each Defendant’s specific involvement with respect to certain claims and theories asserted, particularly considering the length and at times redundance of the second amended complaint, the complaint is not so excessively vague and ambiguous as to be unintelligible and as to prejudice Defendants seriously in attempting to answer it,” the court stated. Any remaining ambiguity concerning how each particular defendant acted illegally could be clarified through discovery.

The case is No. 23-cv-12897.

Judge: White, R.

Attorneys: Alice B. Jennings (Edwards & Jennings) for Robert Barnes, Derrick Toliver and Michael Young, Jr. Brendan Sullivan (Martenson, Hasbrouck & Simon) for G4S Secure Solutions [USA] Inc., Renaissance Center Management Co. and General Motors, LLC f/k/a General Motors Co.

Companies: G4S Secure Solutions [USA] Inc.; Renaissance Center Management Co.; General Motors, LLC; General Motors Co

Cases: RaceDiscrimination ClassActions Discrimination Retaliation CoverageLiability StateLawClaims MichiganNews