Law School Case Brief
Sheet Metal Workers’ Int’l Association v. EEOC - 478 U.S. 421, 106 S. Ct. 3019 (1986)
Criminal contempt sanctions are punitive in nature and are imposed to vindicate the authority of the court. On the other hand, sanctions in civil contempt proceedings may be employed for either or both of two purposes: to coerce the defendant into compliance with the court's order, and to compensate the complainant for losses sustained.
In 1975, the District Court found petitioner union and petitioner apprenticeship committee of the union guilty of violating Title VII of the Civil Rights Act of 1964 by discriminating against nonwhite workers in recruitment, selection, training, and admission to the union. The court ordered petitioners to end their discriminatory practices, established a 29% nonwhite membership goal, based on the percentage of nonwhites in the relevant labor pool in New York City, to be achieved by July 1981, and also ordered petitioners to implement procedures designed to achieve this goal under the supervision of a court-appointed administrator. Thereafter, the administrator proposed and the court adopted an affirmative-action program. The Court of Appeals affirmed, with modifications. On remand, the District Court adopted a revised affirmative-action program, and extended the time to meet the 29% membership goal. The Court of Appeals again affirmed. In 1982 and again in 1983, the District Court found petitioners guilty of civil contempt for disobeying the court's earlier orders. The court imposed a fine to be placed in a special Employment, Training, Education, and Recruitment Fund (Fund), to be used to increase nonwhite membership in the union and its apprenticeship program. The District Court ultimately entered an amended affirmative-action program establishing a 29.23% nonwhite membership goal to be met by August 1987. The Court of Appeals affirmed the District Court's contempt findings (with one exception), the contempt remedies, including the Fund order, and the affirmative-action program with modifications, holding that the 29.23% nonwhite membership goal was proper and did not violate Title VII or the Constitution.
Did the Court err in adopting the 29% statistical figure for the membership goal and in failing to apply the procedures required in criminal contempt against the petitioners?
The court held that the district court properly used the correct statistical evidence to establish petitioner's nonwhite-membership statistical goal. Also, the procedures required for criminal contempt proceedings were not applicable, because the contempt sanctions imposed by the District Court were designed to coerce compliance with the court's various orders, rather than to punish the defendants for their contemptuous conduct. The court held that the Act, § 706(g), 42 U.S.C.S. § 2000e-5(g), did not prohibit the district court from, in appropriate circumstances, ordering race-conscious relief to individuals as a remedy for past discrimination in violation of the Act. The district court correctly approved an administrator to manage petitioners' compliance.
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