|Watson v. Fort Worth Bank & Trust|
|Argued January 20, 1988|
Decided June 29, 1988
|Full case name||Watson v. Fort Worth Bank & Trust|
|Citations||487 U.S. 977 ( more )|
|Prior history||798 F.2d 791 (vacated and remanded)|
|The reasons supporting the use of disparate impact analysis under Title VII apply to subjective employment practices.|
|Majority||O'Connor (Parts I, II-A, II-B, III), joined by Rehnquist, Brennan, White, Marshall, Blackmun, Scalia|
|Plurality||O'Connor (Parts II-C, II-D), joined by Rehnquist, White, Scalia|
|Concurrence||Blackmun (in part and in judgment), joined by Brennan, Marshall|
|Concurrence||Stevens (in judgment)|
|Kennedy took no part in the consideration or decision of the case.|
|Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e et seq.|
Watson v. Fort Worth Bank & Trust, 487 U.S. 977 (1988), is a United States Supreme Court case on US labor law, concerning proof of disparate treatment under the Civil Rights Act of 1964.
The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. Established pursuant to Article III of the U.S. Constitution in 1789, it has original jurisdiction over a narrow range of cases, including suits between two or more states and those involving ambassadors. It also has ultimate appellate jurisdiction over all federal court and state court cases that involve a point of federal constitutional or statutory law. The Court has the power of judicial review, the ability to invalidate a statute for violating a provision of the Constitution or an executive act for being unlawful. However, it may act only within the context of a case in an area of law over which it has jurisdiction. The court may decide cases having political overtones, but it has ruled that it does not have power to decide nonjusticiable political questions.
The Civil Rights Act of 1964 is a landmark civil rights and labor law in the United States that outlaws discrimination based on race, color, religion, sex, or national origin. It prohibits unequal application of voter registration requirements, and racial segregation in schools, employment, and public accommodations.
Plaintiff Watson, an African-American bank teller, applied (on four separate occasions) for a promotion to a supervisory position at the bank.
The bank had not developed precise and formal selection criteria for the positions in question, but instead relied upon the subjective judgment of supervisors who were acquainted with the candidates and the nature of the jobs to be filled.
In all four instances, the supervisors involved in the promotion process were white, and all four times Watson was not selected.
After exhausting her administrative remedies before the Equal Employment Opportunity Commission, Watson filed suit in the United States District Court for the Northern District of Texas. She included allegations that the bank's promotion policies discriminated both against blacks as a class and against her individually, in violation of Title VII of the Civil Rights Act of 1964 (42 USCS 2000e et seq.).
The U.S. Equal Employment Opportunity Commission (EEOC) is a federal agency that administers and enforces civil rights laws against workplace discrimination. The EEOC investigates discrimination complaints based on an individual's race, children, national origin, religion, sex, age, disability, sexual orientation, gender identity, genetic information, and retaliation for reporting, participating in, and/or opposing a discriminatory practice.
The United States District Court for the Northern District of Texas is a United States district court. Its first judge, Andrew Phelps McCormick, was appointed to the court on April 10, 1879. The court convenes in Dallas, Texas with divisions in Fort Worth, Amarillo, Abilene, Lubbock, San Angelo and Wichita Falls. It has jurisdiction over 100 counties in the northern and central parts of the U.S. state of Texas.
After trial, the District Court, dismissing the teller's individual claims, found that she had failed to make a sufficient showing under applicable evidentiary standards. The United States Court of Appeals for the Fifth Circuit affirmed in relevant part, and expressed the view that the proper framework to apply to a Title VII challenge to an allegedly discretionary promotion system would be disparate treatment analysis (which involves the question whether an employer has, with a discriminatory intent or motive, treated a particular person less favorably than others because of that person's race, color, religion, sex, or national origin) rather than disparate impact analysis (which involves the question whether an employer has engaged in facially neutral employment practices that have significant adverse effects on protected groups, and which usually, in the absence of proof that the employer adopted such practices with a discriminatory intent, focuses on statistical disparities)
The United States Court of Appeals for the Fifth Circuit is a federal court with appellate jurisdiction over the district courts in the following federal judicial districts:
On certiorari, the United States Supreme Court vacated the judgment of the Court of Appeals and remanded the case for further proceedings.
Seven members of the Court (1) agreed that disparate impact analysis may be applied to allegedly discriminatory subjective or discretionary employment practices, and (2) agreed regarding certain aspects of the evidentiary standards applicable in such cases. In that portion (Parts I, II-A, II-B, and III) of the opinion by Justice O'Connor, it was held that, in a Title VII action, disparate impact analysis may properly be applied to subjective or discretionary employment practices.
Sandra Day O'Connor is a retired Associate Justice of the Supreme Court of the United States, who served from her appointment in 1981 by President Ronald Reagan until her retirement in 2006. She was the first woman to serve on the Court.
The remainder (Parts II-C and II-D) of Justice O'Connor's opinion, joined by three other Justices, expressed the view that
Justice Blackmun agreed that disparate impact analysis may be applied to claims of discrimination caused by subjective or discretionary selection practices and that the plurality properly characterized the plaintiff's burden of showing that any numerical disparity is significant. He added that
Harry Andrew Blackmun was an American lawyer and jurist who served as an Associate Justice of the Supreme Court of the United States from 1970 until 1994. Appointed by Republican President Richard Nixon, Blackmun ultimately became one of the most liberal justices on the Court. He is best known as the author of the Court's opinion in Roe v. Wade, which prohibits many state and federal restrictions on abortion.
Justice Stevens argued that
A portion of the holding in Watson was superseded by the 1991 amendments to the Civil Rights Act. See Phillips v. Cohen, 400 F.3d 388, 397–98 (6th Cir. 2005); 42 U.S.C. § 2000e-2(k) (2008).
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973), is a US employment law case by the United States Supreme Court regarding the burdens and nature of proof in proving a Title VII case and the order in which plaintiffs and defendants present proof. It was the seminal case in the McDonnell Douglas burden-shifting framework.
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