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Keywords

lawsuitplaintiffdiscriminationregulationclass actioncivil rightsappellant
plaintiffstatutediscriminationregulationclass actioncivil rightsappellantappellee

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Dothard v. Rawlinson, 433 U.S. 321, 97 S.Ct. 2720, 53 L.Ed.2d 786, 15 Fair Empl.Prac.Cas. (BNA) 10, 14 Empl. Prac. Dec. P 7632

Facts

Dianne Rawlinson applied for a position as a correctional counselor in Alabama but was rejected for not meeting the minimum weight requirement of 120 pounds and height requirement of 5 feet 2 inches. She filed a charge with the Equal Employment Opportunity Commission and subsequently brought a class action lawsuit against the Alabama Board of Corrections, arguing that the height and weight requirements violated Title VII and the Equal Protection Clause. The District Court found that these requirements had a discriminatory impact on women, as they excluded a significant percentage of the female population while minimally affecting male applicants.

After her application for employment as a ‘correctional counselor’ (prison guard) in Alabama was rejected because she failed to meet the minimum 120-pound weight requirement of an Alabama statute, which also establishes a height minimum of 5 feet 2 inches, appellee Rawlinson filed a charge with the Equal Employment Opportunity Commission and ultimately brought a class action against appellant corrections officials challenging the statutory height and weight requirements.

Issue

Did the height and weight requirements for correctional counselors in Alabama constitute unlawful sex discrimination under Title VII of the Civil Rights Act, and was the regulation limiting women to certain positions a bona fide occupational qualification?

Did the height and weight requirements for correctional counselors in Alabama constitute unlawful sex discrimination under Title VII of the Civil Rights Act, and was the regulation limiting women to certain positions a bona fide occupational qualification?

Rule

To establish a prima facie case of employment discrimination, a plaintiff must show that facially neutral standards select applicants for hire in a significantly discriminatory pattern. The employer must then demonstrate that any given requirement has a manifest relationship to the employment in question.

To establish a prima facie case of employment discrimination, a plaintiff need only show that the facially neutral standards in question, such as Alabama's height and weight standards, select applicants for hire in a significantly discriminatory pattern.

Analysis

The court applied the rule by examining the statistical evidence presented, which showed that the height and weight requirements disproportionately affected women. The court found that the appellants failed to provide sufficient evidence to justify the requirements as job-related. However, the court acknowledged the unique security challenges posed by the prison environment, concluding that the regulation limiting women to certain positions was justified as a bona fide occupational qualification.

The court found that the appellants failed to rebut the prima facie case of discrimination on the basis that the height and weight requirements are job related in that they have a relationship to the strength essential to efficient job performance as a correctional counselor.

Conclusion

The Supreme Court affirmed the District Court's ruling that the height and weight requirements were discriminatory but reversed the ruling regarding the regulation limiting women to certain positions, holding that it was a bona fide occupational qualification due to security concerns.

The District Court did not err in holding that Title VII prohibited application of the statutory height and weight requirements to appellee and the class she represents.

Who won?

The Alabama Board of Corrections prevailed in part, as the Supreme Court upheld the regulation limiting women to certain positions based on security concerns, which was deemed a bona fide occupational qualification.

The District Court erred in rejecting appellants' contention that the regulation in question falls within the narrow ambit of the bona-fide-occupational-qualification exception of s 703(e).

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