Thursday, November 14, 2013

Griggs v. Duke Power Co. case brief

Griggs v. Duke Power Co. case brief summary
401 U.S. 424 (1971)

CASE SYNOPSIS: Petitioner employees sought certiorari to review a decision of the United States Court of Appeals for the Fourth Circuit, which held that respondent employer's requirement of a high school education or the passing of an intelligence test as a condition of employment did not violate Title VII of the Civil Rights Act, 42 U.S.C.S. § 2000e-2, because there was no showing of a discriminatory purpose in the adoption of the requirements.

CASE FACTS: The employees sought review of the lower court's decision, which concluded that the requirements of a high school education or the passing of a general intelligence test as a condition of employment in or transfer to jobs did not violate Title VII. 

DISCUSSION
  • The Court reversed on the basis that practices, procedures, or tests that were neutral on their face could not be maintained if they operated to freeze the status quo of prior discriminatory employment practices. 
  • The Court found that it was significant that the requirements were not shown to bear a demonstrable relationship to the successful performance of the jobs for which the standards were used and that the requirements operated to disqualify black applicants at a substantially higher rate than white applicants for jobs that were formerly filled only by white employees. 
  • The employer's lack of discriminatory intent was not controlling because courts were required to look to the consequences of the employment practices, not simply the motivation. 
  • Tests could be used to measure job performance if they measured the person for the job and not the person in the abstract.
CONCLUSION: The Court reversed the lower court's judgment in favor of the employer.

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