Was 'on the fly' promotion decision biased against qualified minority employee?

When promotions are handed out, managers are already familiar with employees’ work, so there’s no need to set up a formal evaluation process, right? Wrong.
When a plant manager job opened up at a dry-ice producer, the boss hand-picked a replacement — a white male employee — from within the company. The vacancy wasn’t posted, and no applications from other interested employees were taken.
When an African-American employee found out about his co-worker’s promotion, he complained. The promoted employee had only been with the company for three years, while the African-American worker had 15 years of experience in the plant. He said he was more qualified than the new plant manager.
When the complaints were ignored, he took them to the Equal Employment Opportunity Commission, who filed a lawsuit on his behalf. Failing to have the case tossed, the company agreed to pay $40,000 to settle.
Cite: EEOC v. Airgas Carbonic, Inc.