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Keywords

lawsuitstatutediscriminationcivil rights
statutediscriminationcivil rights

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United Steelworkers of America, AFL-CIO-CLC v. Weber, 443 U.S. 193, 99 S.Ct. 2721, 61 L.Ed.2d 480, 20 Fair Empl.Prac.Cas. (BNA) 1, 20 Empl. Prac. Dec. P 30,026, 26 Cont.Cas.Fed. (CCH) P 83,385

Facts

In 1974, the United Steelworkers of America and Kaiser Aluminum entered into a collective-bargaining agreement that included an affirmative action plan to address racial imbalances in the workforce. The plan reserved 50% of openings in craft-training programs for black employees until their representation in the workforce matched that of the local labor force. Prior to this plan, only 1.83% of skilled craftworkers at the Gramercy plant were black, despite the local workforce being approximately 39% black. A white employee, Brian Weber, filed a lawsuit claiming discrimination after he was denied admission to the training program in favor of less senior black employees.

In 1974, petitioners United Steelworkers of America (USWA) and Kaiser Aluminum & Chemical Corp. (Kaiser) entered into a master collective-bargaining agreement covering terms and conditions of employment at 15 Kaiser plants. The agreement included an affirmative action plan designed to eliminate conspicuous racial imbalances in Kaiser's then almost exclusively white craftwork forces by reserving for black employees 50% of the openings in in-plant craft-training programs until the percentage of black craftworkers in a plant is commensurate with the percentage of blacks in the local labor force.

Issue

Does Title VII of the Civil Rights Act of 1964 prohibit private employers and unions from voluntarily adopting affirmative action plans that include racial preferences?

The question for decision is whether Congress, in Title VII of the Civil Rights Act of 1964, left employers and unions in the private sector free to take such race-conscious steps to eliminate manifest racial imbalances in traditionally segregated job categories.

Rule

Title VII's prohibitions against racial discrimination do not condemn all private, voluntary, race-conscious affirmative action plans.

Title VII's prohibition in § 703(a) and (d) against racial discrimination does not condemn all private, voluntary, race-conscious affirmative action plans.

Analysis

The Court analyzed the legislative history of Title VII and determined that the statute was intended to address the historical exclusion of blacks from certain job categories. The affirmative action plan in question was found to align with the goals of Title VII, as it sought to eliminate racial imbalances without imposing undue burdens on white employees. The plan was deemed a temporary measure aimed at correcting past discrimination rather than maintaining racial balance.

Examination of those sources makes clear that an interpretation of §§ 703(a) and (d) that forbids all race-conscious affirmative action would bring about an end completely at variance with the purpose of the statute and must be rejected.

Conclusion

The Supreme Court reversed the lower court's decision, holding that the Kaiser-USWA affirmative action plan was permissible under Title VII.

We therefore hold that Title VII's prohibition in §§ 703(a) and (d) against racial discrimination does not condemn all private, voluntary, race-conscious affirmative action plans.

Who won?

Kaiser Aluminum & Chemical Corp. and the United Steelworkers of America prevailed because the Supreme Court found their affirmative action plan to be consistent with the goals of Title VII.

The Court, however, declines to consider the narrow 'arguable violation' approach and adheres instead to an interpretation of Title VII that permits affirmative action by an employer whenever the job category in question is 'traditionally segregated.'

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