Ángel Hernández vs. MLB: Allegations, Rulings, and 2024 Settlement

Ángel Hernández’s MLB lawsuit was a race and national-origin discrimination case the Cuban-born umpire filed in 2017, alleging he had been denied crew chief promotions and World Series assignments because of bias, particularly from MLB chief baseball officer Joe Torre. Federal courts dismissed the case at summary judgment in 2021, denied reconsideration in 2022, and the Second Circuit affirmed in August 2023.¹ Hernández retired in May 2024 after reaching a separate, undisclosed financial settlement with the league.²

What Hernández Alleged

Hernández filed two discrimination charges with the EEOC in June 2017 and sued the Office of the Commissioner of Baseball the following month in federal court in Cincinnati.³ The complaint brought claims under Title VII, Section 1981, the New York State Human Rights Law, and the New York City Human Rights Law.⁴

Two arguments carried the case. Hernández alleged that none of the 23 umpires promoted to crew chief since 2000 had been minorities, and that only one minority umpire had been assigned to a World Series crew in the six years since Torre began overseeing those decisions.³⁵¹⁶

How MLB Defended the Case

MLB relied heavily on Torre, who served as final decision-maker for crew chief promotions from 2013 to 2018 and for World Series assignments from 2011 to 2019.⁷⁸ Hernández’s 2014 and 2016 year-end evaluations cited concerns about communication, accountability, and focus.

Torre also testified he did not place significant weight on the Field Evaluation Forms, on which Hernández scored more strongly, and emphasized leadership as the most important factor. Hernández’s lawyers argued the shift to subjective criteria was itself evidence of pretext.⁷

Why the Courts Rejected the Claims

On March 31, 2021, Judge J. Paul Oetken of the Southern District of New York granted MLB summary judgment on all remaining claims. He found no evidence from which a reasonable juror could conclude MLB’s reasons were a cover for discrimination, and held that subjective evaluation criteria are not unlawful so long as the employer’s explanation is clear and reasonably tied to an honest assessment.⁷

The court accepted expert testimony that the umpire pool — roughly 100 total, about 10 of them African American or Hispanic — was too small for the observed promotion disparities to be statistically meaningful. It also noted that MLB had assigned a Latino umpire to the World Series in both 2011 and 2015, and that Torre had frequently promoted less-senior white umpires over more-senior white umpires, indicating seniority was not controlling for anyone. On the disparate impact claim, the court held Hernández had failed to identify a specific employment practice tied to the disparity, ruling that a challenge to the overall promotion process was too broad.⁷

Hernández moved for reconsideration under Rule 59(e), arguing that the small-sample-size rationale would incentivize employers to keep minority hiring pools small. Judge Oetken denied the motion on January 21, 2022, finding this a policy argument rather than new evidence or clear legal error.⁹ On August 15, 2023, the Second Circuit affirmed in a summary order, finding Hernández had not established a statistically significant disparity and had made no showing that Torre harbored bias against racial minorities.¹ The panel wrote that “bottom-line numbers” alone are insufficient to prove disparate impact without linking the statistics to a specific biased employment practice.⁸

The 2024 Retirement Settlement

Hernández’s retirement was announced on May 27, 2024, weeks after his final game on May 9 behind home plate for a Chicago White Sox–Cleveland Guardians matchup.¹⁰²¹¹ The dollar amount and specific terms were not disclosed.

In his public statement, Hernández said he wanted to spend more time with his family and cited his role in the “expansion and promotion of minorities” in umpiring.¹² His attorney, Kevin Murphy of Fort Mitchell, Kentucky, said Hernández was not forced out.² The settlement resolved Hernández’s employment; it was separate from the discrimination lawsuit, which had already run its course through the Second Circuit.

Diversity Among Crew Chiefs During the Case

Between 2011 and 2017, only white umpires were elevated to crew chief.⁸ That changed in February 2020, while Hernández’s suit was pending on appeal, when MLB promoted Kerwin Danley as the first African American crew chief in league history and Alfonso Márquez as the first Mexican-born crew chief and only the second Hispanic crew chief ever.¹³ The promotions followed the retirements of four existing crew chiefs.¹⁴ Hernández himself served as an interim crew chief in July 2020 after a dozen umpires opted out of the pandemic-shortened season, but never received the permanent role.¹⁵

1
ESPN. Appeals Court Rejects Angel Hernandez Lawsuit vs. MLB
2
New York Post. Angel Hernandez Retired: How MLB Finally Ended Umpire’s Tenure
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ESPN. Umpire Angel Hernandez Sues MLB for Discrimination
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U.S. District Court, S.D.N.Y. Hernandez v. Office of the Commissioner of Baseball, 18-CV-9035
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The Athletic. MLB Umpire Angel Hernandez Lawsuit
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Cincinnati Enquirer. Ump Files Racial Discrimination Suit Against MLB
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Courthouse News Service. Hernandez v. Office of the Commissioner of Baseball, Opinion and Order
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Bloomberg Law. MLB Umpire Angel Hernandez Loses Appeal of Discrimination Suit
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The Athletic. Umpire Angel Hernandez’s Discrimination Lawsuit Against MLB Dismissed for Second Time
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USA Today. Angel Hernandez Retires as MLB Umpire
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Newsday. Umpire Ángel Hernández Retiring
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ESPN. MLB Umpire Angel Hernandez Retiring
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ESPN. MLB Appoints Kerwin Danley, Alfonso Marquez First African American, Latino Crew Chiefs
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Los Angeles Times. MLB Appoints Its First African American and Mexican American Umpire Crew Chiefs
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ESPN. Umpire Angel Hernandez Loses Race Discrimination Lawsuit Against MLB