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Keywords

plaintiffdefendantdiscriminationcompliance

plaintiffdefendantdiscrimination

Related Cases

Guardians Ass’n of New York City Police Dept., Inc. v. Civil Service Commission of City of New York, 630 F.2d 79, 23 Fair Empl.Prac.Cas. (BNA) 909, 23 Empl. Prac. Dec. P 31,154

Facts

The case involved Exam No. 8155, administered to 36,797 applicants for the New York City police force. The plaintiffs, including organizations of Black and Hispanic police officers and individual applicants, argued that the test's design and implementation led to a significant racial disparity in passing rates. The District Court found that the test's use resulted in a passing rate of only 15.4% for minority applicants compared to 66.6% for White applicants, establishing a prima facie case of discrimination under Title VII.

The test at issue was designed by New York City officials and administrated on June 30, 1979 to 36,797 applicants for positions on the City's police force.

Issue

Did the use of Exam No. 8155 for hiring police officers result in unlawful discrimination against Black and Hispanic applicants in violation of Title VII?

Rule

To establish a violation of Title VII based on disparate impact, plaintiffs must show that a selection procedure disproportionately affects a protected group, and the defendant must then demonstrate that the procedure is job-related and valid.

In reaching this conclusion, the Court used the common mode of Title VII analysis, in which the plaintiff is first required to establish a prima facie case on the basis of disparate impact, and then the defendant is required to rebut the plaintiff's case by proving that the disparity results from legitimate, job-related selection procedures.

Analysis

The court applied the Title VII analysis, determining that the plaintiffs established a prima facie case of discrimination due to the significant disparity in passing rates between minority and White applicants. The court found that the test lacked sufficient content validity and did not adequately measure the abilities necessary for police work, thus failing to rebut the plaintiffs' case.

The Court first found that the disparity between the percentage of minority group members who achieved a passing score and the percentage of minority group members in the applicant pool was sufficient to establish a prima facie case.

Conclusion

The court affirmed the District Court's finding of discrimination but vacated the specific remedy of a 50% minority hiring quota, remanding for a revised decree that would ensure compliance with Title VII.

The Court ordered a broad remedy, including a 50% minority hiring quota.

Who won?

The plaintiffs prevailed in establishing that the test discriminated against minority applicants, leading to the court's finding of a Title VII violation.

The District Court found that use of the test unjustifiably discriminates against Blacks and Hispanics in violation of Title VII.

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