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Keywords

plaintiffdefendantstatutemotiondiscriminationcorporationcivil rightslegislative intentmotion to dismiss
plaintiffdefendantstatutemotiondiscriminationcorporationcivil rightsstatutory interpretationmotion to dismiss

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Spiess v. C. Itoh & Co.

Facts

Plaintiffs, white American citizens of non-Japanese national origin, filed suit on behalf of themselves and all other non-secretarial personnel of non-Japanese national origin employed by the defendant, an American corporation wholly owned by C. Itoh & Co., Ltd., of Japan. They alleged that the defendant discriminated in its employment practices against this class based on national origin, race, and color, in violation of Title VII and 1981. The employer contended that the plaintiffs had no standing to bring a claim under 1981 and that they could not state a claim upon which relief could be granted because they were white American citizens.

Plaintiffs, white American citizens of non-Japanese national origin, have filed suit on behalf of themselves and all other non-secretarial personnel of non-Japanese national origin who have been, are now, or might be employed by defendant, an American corporation wholly owned by C. Itoh & Co., Ltd., of Japan.

Issue

Whether white employees have standing to bring a claim under 42 U.S.C. 1981 and whether they can state a claim for relief under Title VII of the Civil Rights Act.

Whether white employees have standing to bring a claim under 42 U.S.C. 1981 and whether they can state a claim for relief under Title VII of the Civil Rights Act.

Rule

The court reviewed the legislative history of 1981 and concluded that the statutory language and judicial interpretations support the view that plaintiffs have standing to bring an action and may state a claim based on allegations of discrimination on the basis of their white race.

After carefully evaluating as of this time appropriate judicial, scholarly and legislative authorities, the Court concludes that the statutory language, the legislative history and the more persuasive judicial interpretations of 42 U.S.C. 1981 in light thereof support the view that plaintiffs have standing to bring this action and that they may also state a claim upon which relief can be granted as to them solely because they allege discrimination on the basis of their white race.

Analysis

The court applied the rule by examining the legislative history and intent behind 1981, determining that the inclusion of white citizens in the statute's protections was consistent with the goal of ensuring equal rights for all individuals, regardless of race. The court found that the employer's arguments against standing were not supported by the legislative intent of the Civil Rights Act.

To clarify the somewhat confusing and complicated statutory interpretation which is generated when white citizens sue under 1981, this Court must begin with an examination of the wording of the subject statute and its centenarian antecedents.

Conclusion

The court denied the employer's motion to dismiss the white employees' employment discrimination claims for lack of standing and failure to state a claim upon which relief could be granted.

The court denied the employer's motion to dismiss the white employees' employment discrimination claims for lack of standing and failure to state a claim upon which relief could be granted.

Who won?

The plaintiffs prevailed in the case because the court found that they had standing to bring their claims and could state a claim for relief under the relevant statutes.

The plaintiffs prevailed in the case because the court found that they had standing to bring their claims and could state a claim for relief under the relevant statutes.

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