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Keywords

lawsuitliabilitymotionburden of proofdiscriminationcivil rights

trustdiscriminationrespondent

Related Cases

Watson v. Fort Worth Bank and Trust, 487 U.S. 977, 108 S.Ct. 2777, 101 L.Ed.2d 827, 47 Fair Empl.Prac.Cas. (BNA) 102, 46 Empl. Prac. Dec. P 38,065, 57 USLW 4922

Facts

Clara Watson, a black employee at Fort Worth Bank, was denied four promotions in favor of white applicants. The bank relied on the subjective judgment of white supervisors for promotion decisions, without formal selection criteria. After exhausting her administrative remedies, Watson filed a lawsuit alleging racial discrimination under Title VII of the Civil Rights Act of 1964. The District Court initially dismissed her claims, stating she did not meet the burden of proof for discriminatory treatment.

Petitioner Clara Watson, who is black, was hired by respondent Fort Worth Bank and Trust (the Bank) as a proof operator in August 1973. In January 1976, Watson was promoted to a position as teller in the Bank's drive-in facility. In February 1980, she sought to become supervisor of the tellers in the main lobby; a white male, however, was selected for this job.

Issue

Whether subjective or discretionary employment practices can be analyzed under the disparate impact approach in Title VII discrimination cases.

This Court has not addressed the question whether disparate impact analysis may be applied to cases in which subjective criteria are used to make employment decisions.

Rule

Disparate impact analysis may be applied to subjective or discretionary promotion systems, allowing for the evaluation of facially neutral practices that may have adverse effects on protected groups.

We conclude, accordingly, that subjective or discretionary employment practices may be analyzed under the disparate impact approach in appropriate cases.

Analysis

The court determined that applying disparate impact analysis to subjective employment practices is necessary to prevent employers from evading liability by combining objective criteria with subjective components. The court noted that subjective practices could produce effects indistinguishable from intentional discrimination, thus warranting the application of disparate impact standards.

We are also persuaded that disparate impact analysis is in principle no less applicable to subjective employment criteria than to objective or standardized tests.

Conclusion

The Supreme Court vacated the judgment of the lower courts and remanded the case for further evaluation of the statistical evidence regarding Watson's claims of discrimination.

The judgment is vacated, and the case is remanded.

Who won?

The prevailing party was the bank, as the initial court ruling was in its favor, but the Supreme Court's decision to vacate and remand indicates that the case is not concluded.

The majority affirmed the District Court's conclusion that Watson had failed to prove her claim of racial discrimination under the standards set out in McDonnell Douglas, supra, and Burdine, supra.

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