Case
In 1969, the Hazelwood School District in Missouri hired its first black teacher, and continued hiring black teachers ever since. In 1972, the Civil Rights Act of 1964 was amended to apply to public employers, including school districts, making the hiring of black teachers almost a necessity in order to avoid liability. However, due to statistical disparities in the hiring practices of this particular school district, as well as 55 individual cases of alleged discrimination, the United States brought suit in the United States District Court for the Eastern District of Missouri to enjoin the school district from discriminating based on race. The District Court found in favor of the school district, saying that the ratio of black teachers to white was roughly equivalent to the ratio of black students to white. [2]
The United States appealed to the United States Court of Appeals for the Eighth Circuit, which reversed the District Court's decision. [3] This judgment was based on their decision to disregard the comparison to the student population, and instead compare the Hazelwood hiring statistics to the statistics of the surrounding area, including the St. Louis, MO school districts, saying that those numbers would more accurately reflect the "relevant labor market[.]" [1] : 304 Hazelwood appealed to the Supreme Court to review the Court of Appeals decision, arguing that the relevant labor market statistics should not include the St. Louis numbers, because that city had imposed very strict hiring guidelines to help overcome past racial discrimination. [1] : 311
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