McDonald v. Santa Fe Trail Transportation case brief

McDonald v. Santa Fe Trail Transportation case brief summary
427 U.S. 273; 96 S. Ct. 2574; 49 L. Ed. 2d 493 (1976)

CASE SYNOPSIS: Petitioners challenged a judgment of the United States Court of Appeals for the Fifth Circuit dismissing its discrimination action against respondent corporation, which alleged violations of the Civil Rights Act of 1866, 42 U.S.C.S. § 1981, and of Title VII of the Civil Rights Act of 1964, 42 U.S.C.S. § 2000e et seq. The court ruled that neither statute was applicable to Caucasians.

CASE FACTS: Petitioners commenced action against respondent employer alleging that their discharge violated 42 U.S.C.S. § 1981 and Title VII. Petitioners, two Caucasian males, alleged that respondent discriminatorily fired them for misappropriating company property, while retaining an employee from a racial minority group who was involved in the same scheme. Petitioners challenged a court of appeals ruling that neither statute was applicable to Caucasians.

DISCUSSION

• The United States Supreme Court reversed and remanded the action for further consideration because the appellate court erred in ruling that the statutes did not apply to Caucasians. 
• The court noted that Title VII prohibited all racial discrimination in employment, without exception for any group of particular employees. 
• Consequently, Title VII prohibited racial discrimination against the Caucasian employees upon the same standards as applied to the employee from a minority racial group. 
• The Caucasian employees had to show that race was a "but for" cause of their discharge. 
• The court also ruled that while crime or other misconduct might be a legitimate basis for discharge, it was not one for racial discrimination.

CONCLUSION: The Court reversed and remanded the action for further consideration, because the appellate court erred in ruling that the statutes did not apply to Caucasians. The Court ruled that Title VII prohibited racial discrimination against Caucasians and members of racial minority groups upon the same standards.