When People’s United Bank in New York City closed the accounts of a Black Muslim Senegalese-American woman and a “Muslim nonprofit” she controlled, she sued the bank for alleged discrimination on the basis of race, religion and national origin. The Second Circuit Court of Appeals has affirmed the judgment of a federal District Court dismissing the claims under federal Section 1981 and the New York State and New York City Human Rights laws. The Court said she had not met her burden of proof under the McDonnell Douglas burden shifting-framework for discrimination cases when there is no direct evidence to support the claim. The Court found that she had failed to make out a prima facie case of...