Civil Rights Act claim by police officer is dismissed

In Moran v. City of Kalamazoo, the plaintiff alleged that he was denied a requested transfer to the bomb squad, and later a deserved promotion to sergeant, because of his race. The trial court dismissed his claims on summary judgment. On review, the Court of Appeals noted that the history of Department promotions did not support Moran's claim of discrimination and that he failed to show that he was more qualified than the individual ultimately promoted.  As for the bomb squad:  he "was not chosen...because he performed poorly on the bomb-suit portion of the test."  A variation on the "all dressed up and no place to go" idea.