Law School Case Brief
Connecticut v. Teal - 457 U.S. 440, 102 S. Ct. 2525 (1982)
Title VII of the Civil Rights Act of 1964, 42 U.S.C.S. § 2000e et seq., does not permit a victim of a facially discriminatory policy to be told that he has not been wronged because other persons of his or her race or sex were hired. That answer is no more satisfactory when it is given to victims of a policy that is facially neutral but practically discriminatory. Every individual employee is protected against both discriminatory treatment and practices that are fair in form, but discriminatory in operation. Requirements and tests that have a discriminatory impact are merely some of the more subtle, but also the more pervasive, of the practices and devices which have fostered racially stratified job environments to the disadvantage of minority citizens.
Plaintiff Winnie Teal and three others who were black employees of an agency operated by defendant State of Connecticut filed suit against defendant in the United States District Court for the District of Connecticut. Plaintiffs, who had been promoted provisionally to the supervisory positions and served in that capacity for almost two years, later failed a written examination and were thereby excluded from the selection process for attaining permanent status as supervisors. They alleged that the State, certain state agencies and State officials violated Title VII of the Civil Rights Act of 1964 by requiring as an absolute condition for consideration for promotion that applicants pass a written test that disproportionately excluded blacks and was not job-related, the passing rate on the test for blacks being only 68 percent of the passing rate for whites. Before trial, promotions were made from the eligibility list generated by the written examination, the overall result being that 22.9 percent of the black candidates and 13.5 percent of the white candidates were promoted. The district court ruled that the "bottom line" percentages, which were more favorable to blacks than whites, precluded a finding of a Title VII violation. On appeal, the United States Court of Appeals for the Second Circuit reversed, holding that the district court erred in ruling that the examination results alone were insufficient to support a prima facie case of disparate impact in violation of Title VII. The State appealed, alleging that its bottom-line result that was more favorable to blacks than to whites was a complete defense to plaintiffs' suit. It argued that the test was not used to discriminate because it did not actually deprive disproportionate numbers of blacks of promotions.
Was the required written test discriminatory in nature and violative of Title VII of the Civil Rights Act of 1964?
The Supreme Court of the United States held that the test that barred promotion and had a discriminatory impact on black employees fell within 42 U.S.C.S. § 2000e-2(a)(2). It was a barrier to achieving equality of employment opportunities for minorities. Title VII guaranteed plaintiffs the opportunity to compete equally with white workers on the basis of job-related criteria. The State agency could not avoid its burden to show that the test was not an artificial, arbitrary, or unnecessary barrier, but was job-related, by promoting a sufficient number of the black employees who passed the test. plaintiffs' claim of disparate impact from the test stated a prima facie case of employment discrimination despite agency's nondiscriminatory bottom line. The bottom line was no defense to plaintiffs' prima facie case. The case was remanded to the district court for further proceedings.
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