Thursday, November 14, 2013

Personnel Administrator of Massachusetts v. Feeney case brief

Personnel Administrator of Massachusetts v. Feeney case brief summary
442 U.S. 256 (1979)

CASE SYNOPSIS
Appellant, the Personnel Director for the State of Massachusetts, challenged an order of a United States district court, which held that the veterans' hiring preference statute, Mass. Gen. Laws Ann. ch. 31, § 23, violated the Equal Protection Clause of U.S. Constitutional Amendment XIV by discriminating against women. Appellee, a female who was not a veteran, had lost civil service positions to male veterans despite her high test scores.

CASE FACTS
Appellee was a female civil service worker who had lost several positions to male veterans despite her high test scores. She filed a claim against appellant, the State of Massachusetts, and twice argued successfully before the district court that Mass. Gen. Laws Ann. ch. 31, § 23, the veterans' hiring preference statute, violated the Equal Protection Clause of U.S. Constitutional Amendment XIV by discriminating on the basis of sex.


DISCUSSION

  • On appeal, the Court reversed. After a close examination of the statute, the Court found that although the result of the statute had a disproportionate impact on women, it had not been enacted in order to discriminate against women. 
  • The statute contained gender neutral language. 
  • Because the statute was gender-neutral on its face, the Court considered first whether the statutory classification was neutral and then whether the adverse effect reflected invidious gender-based discrimination. 
  • The statutory classification was neutral because it was intended to discriminate against non-veterans, not against women. 
  • Female veterans were entitled to its benefits. 
  • Moreover, the legislative purpose had not been to invidiously discriminate against women.
CONCLUSION
The Court reversed the district court's order and held that appellee, a female civil service worker who was not a veteran, had not suffered a civil rights violation under the veterans' hiring preference statute of appellant, the State of Massachusetts. Although the statute had a disparate impact on women, it did not have a discriminatory intent.

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