Washington v. Davis case brief

Washington v. Davis case brief summary

426 U.S. 229 (1976)

CASE SYNOPSIS

Petitioner city officials appealed a judgment of the United States Court of Appeals for the District of Columbia Circuit, which reversed a trial court's decision and invalidated a qualifying test for respondent police recruits for positions with the city's police department.

PROCEDURAL HISTORY
The trial court denied the police recruits' motion for summary judgment because the qualifying test was directly related to the requirements of the police training program, and a positive relationship between the test and training course performance was sufficient to validate the former. The appellate court reversed that ruling because the disproportionate impact resulting from the fact that a greater proportion of blacks failed the test than whites established a constitutional violation.

DISCUSSION

• The court reversed, holding that the appellate court erroneously applied legal standards applicable to Title VII cases. 
• The court held a statute, which was otherwise neutral on its face had to be applied so as to invidiously discriminate on the basis of race. 
• The police department's efforts to recruit black officers, the changing racial composition of the recruit classes, and the relationship of the test to the training program negated any inference that the police department discriminated on the basis of race or that a police officer qualified on the color of his skin rather than ability. 
• Thus, it was error for the appellate court to direct summary judgment for the police recruits.

CONCLUSION

The court reversed the appellate court's judgment, which invalidated the qualifying test taken by police recruits.