Friday, December 27, 2013

Carson v. American Brands, Inc. case brief

Carson v. American Brands, Inc. case brief summary
450 U.S. 79 (1981)

CASE SYNOPSIS
Certiorari was granted to review an order from the United States Court of Appeals for the Fourth Circuit, which held that a district court's refusal to enter a consent decree in an employment discrimination class action by petitioners, black seasonal employees and job applicants, against respondents, a tobacco company and labor union, was not appealable.

CASE FACTS
A class of black seasonal employees and job applicants filed suit against a tobacco company and labor union under the Civil Rights Act of 1964, 42 U.S.C.S. § 2000e et seq., seeking a declaratory judgment, injunctive relief, and damages. The parties reached a settlement and filed a joint motion to have the district court approve and enter a consent decree that would have required hiring and seniority preferences for black employees, among other things. The district court denied the motion, and the court of appeals dismissed the appeal.

DISCUSSION

  • Certiorari was granted, and the Court held that the order was appealable under 28 U.S.C.S. § 1292(a)(1). 
  • Though the proposed consent decree did not actually refuse an injunction, it had the practical effect of doing so because the decree would have permanently enjoined respondents from discrimination against black employees and would have directed changes in seniority and benefit systems, established hiring goals for black employees, and granted job-bidding preferences for seasonal employees. 
  • Moreover, the class might suffer irreparable harm by losing their negotiated settlement and failing to achieve the immediate job restructuring requested.
CONCLUSION
The Court reversed the order of the court of appeals.

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