In Bogan v. Janet Scott-Harris,1 the Mayor and the City Council of Fall River, Massachusetts, passed a bill that eliminated the Department of Health and Human Services (DHHS), which was headed by Janet Scott-Harris, the first African American to work for the City. Janet Scott-Harris had been Fall River's first black administrator when she was hired in 1987 to head the DHHS. In 1990, Scott-Harris accused a long time City employee, Dorothy Biltcliffe, of repeatedly using racial slurs, including ca...