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Keywords

plaintiffappealdiscriminationclass actioncivil rights
statuteappealclass actioncivil rights

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Griggs v. Duke Power Co., 401 U.S. 424, 91 S.Ct. 849, 28 L.Ed.2d 158, 3 Fair Empl.Prac.Cas. (BNA) 175, 3 Empl. Prac. Dec. P 8137, 88 P.U.R.3d 90

Facts

The case involved a class action by Black employees against Duke Power Company, alleging that the company's employment practices violated the Civil Rights Act. Prior to the Act's effective date, the company had openly discriminated against Black employees, restricting them to lower-paying jobs in the Labor Department. After the Act was enacted, the company instituted a high school education requirement and standardized tests for transfers to higher-paying departments, which disproportionately affected Black employees who had historically received inferior education. The District Court found no discriminatory intent in these requirements, but the Court of Appeals reversed part of this decision, leading to the Supreme Court's review.

Congress provided, in Title VII of the Civil Rights Act of 1964, for class actions for enforcement of provisions of the Act and this proceeding was brought by a group of incumbent Negro employees against Duke Power Company.

Issue

Whether Duke Power Company's requirement of a high school education and standardized intelligence tests as conditions for employment and transfer violated Title VII of the Civil Rights Act of 1964, given that these requirements disproportionately disqualified Black applicants.

We granted the writ in this case to resolve the question whether an employer is prohibited by the Civil Rights Act of 1964, Title VII, from requiring a high school education or passing of a standardized general intelligence test as a condition of employment in or transfer to jobs when (a) neither standard is shown to be significantly related to successful job performance, (b) both requirements operate to disqualify Negroes at a substantially higher rate than white applicants, and (c) the jobs in question formerly had been filled only by white employees as part of a longstanding practice of giving preference to whites.

Rule

Under Title VII of the Civil Rights Act of 1964, employment practices that are neutral in intent but discriminatory in effect are prohibited. Employers must demonstrate that any employment criteria are significantly related to job performance.

The objective of Congress in the enactment of Title VII is plain from the language of the statute. It was to achieve equality of employment opportunities and remove barriers that have operated in the past to favor an identifiable group of white employees over other employees.

Analysis

The Supreme Court analyzed the requirements imposed by Duke Power Company and found that neither the high school diploma nor the intelligence tests had a demonstrable relationship to successful job performance. The Court noted that these requirements operated to disqualify Black applicants at a significantly higher rate than white applicants and were part of a long-standing practice of racial discrimination. The Court emphasized that good intent or absence of discriminatory intent does not excuse employment practices that create built-in disadvantages for minority groups.

The evidence, however, shows that employees who have not completed high school or taken the tests have continued to perform satisfactorily and make progress in departments for which the high school and test criteria are now used.

Conclusion

The Supreme Court reversed the decision of the Court of Appeals, holding that Duke Power Company's requirements violated Title VII because they were not job-related and perpetuated past discrimination against Black employees.

The judgment of the Court of Appeals is, as to that portion of the judgment appealed from, reversed.

Who won?

The plaintiffs, a group of Black employees, prevailed in the case as the Supreme Court ruled that the employer's practices violated the Civil Rights Act, emphasizing the need for employment criteria to be job-related.

The Court of Appeals ruled that Negroes employed in the Labor Department at a time when there was no high school or test requirement for entrance into the higher paying departments could not now be made subject to those requirements, since whites hired contemporaneously into those departments were never subject to them.

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