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Keywords

contractmotiondiscriminationharassment

contractappealmotionharassmentrespondent

Related Cases

Patterson v. McLean Credit Union, 491 U.S. 164, 109 S.Ct. 2363, 105 L.Ed.2d 132, 49 Fair Empl.Prac.Cas. (BNA) 1814, 50 Empl. Prac. Dec. P 39,066, 57 USLW 4705

Facts

Brenda Patterson was employed by McLean Credit Union for ten years until her layoff in 1982. She alleged that during her employment, she faced racial harassment, was denied a promotion to an accounting clerk position, and was ultimately discharged due to her race. The District Court ruled that her racial harassment claim was not actionable under § 1981 and instructed the jury that she needed to prove she was better qualified than the white employee who received the promotion. The jury found in favor of the employer on both claims.

Petitioner, a black woman, was employed by respondent credit union as a teller and file coordinator for 10 years until she was laid off. Thereafter, she brought this action in District Court under 42 U.S.C. § 1981, alleging that respondent had harassed her, failed to promote her to accounting clerk, and then discharged her, all because of her race.

Issue

Whether racial harassment in employment is actionable under § 1981 and whether the jury instruction requiring Patterson to prove she was better qualified than the promoted employee was erroneous.

We granted certiorari to decide whether petitioner's claim of racial harassment in her employment is actionable under § 1981, and whether the jury instruction given by the District Court on petitioner's § 1981 promotion claim was error.

Rule

§ 1981 prohibits racial discrimination in the making and enforcement of private contracts, but does not cover racial harassment that occurs after the formation of a contract.

Racial harassment relating to the conditions of employment is not actionable under § 1981, which provides that '[a]ll persons … shall have the same right … to make and enforce contracts … as is enjoyed by white citizens,' because that provision does not apply to conduct which occurs after the formation of a contract and which does not interfere with the right to enforce established contract obligations.

Analysis

The Court determined that Patterson's claims of racial harassment did not involve the making or enforcement of contracts as defined by § 1981, which is limited to conduct at the formation of a contract and the enforcement of established contract rights. The Court found that the alleged harassment related to the conditions of her employment, which is governed by Title VII, not § 1981. Furthermore, the Court ruled that the District Court erred in instructing the jury that Patterson had to prove she was better qualified than the white employee to establish her promotion claim.

Applying these principles to the case before us, we agree with the Court of Appeals that petitioner's racial harassment claim is not actionable under § 1981. Petitioner has alleged that during her employment with respondent, she was subjected to various forms of racial harassment from her supervisor.

Conclusion

The Supreme Court affirmed in part and vacated in part the lower court's decision, holding that racial harassment is not actionable under § 1981 and that the jury instruction regarding the promotion claim was incorrect.

We conclude, upon direct consideration of the issue, that no special justification has been shown for overruling Runyon.

Who won?

McLean Credit Union prevailed in the case because the Supreme Court found that Patterson's claims of racial harassment were not actionable under § 1981 and that the jury was incorrectly instructed on the promotion claim.

The Court of Appeals affirmed the judgment in favor of respondent.

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