Thursday, November 14, 2013

United Steelworkers of America v. Weber case brief

United Steelworkers of America v. Weber case brief summary
443 U.S. 193, 99 S. Ct. 2721, 61 L. Ed. 2d 480 (1979)


CASE SYNOPSIS: Petitioners, an employer and a union, filed an application for a writ of certiorari to review a judgment from the United States Court of Appeals for the Fifth Circuit to contest its affirmance of the judgment that a collectively bargained affirmative action plan violated the rights of respondent, a white employee, under Title VII of the Civil Rights Act of 1964.

CASE FACTS: The employer and the union collectively bargained for an affirmative action plan that reserved for black employees 50 percent of the openings in a training program until the percentage of black craftworkers in the plant was commensurate with the percentage of blacks in the local labor force. Respondent, a white employee, challenged the legality of the plan under Title VII of the Civil Rights Act of 1964 (Title VII), 42 U.S.C.S. § 2000e et seq.

PROCEDURAL HISTORY
The district court held that the plan violated Title VII, and the court of appeals affirmed. 

DISCUSSION
  • The United States Supreme Court reversed, holding that Title VII's prohibition against racial discrimination did not condemn all private, voluntary, race-conscious affirmative action plans. 
  • The Court also noted that petitioners' plan in particular did not violate Title VII because no state action was involved, the purposes of the plan mirrored Title VII's, and the plan did not unnecessarily trammel the interests of the white employees. 
  • The plan did not require the discharge of white workers and their replacement with new black hirees. 
  • Nor did it create an absolute bar to the advancement of white employees. 
  • Moreover, the plan was a temporary measure.
CONCLUSION: The Court reversed the appellate court's affirmance of the district court's finding that a collectively bargained affirmative action plan violated Title VII of the Civil Rights Act of 1964.

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