Case Study Analysis

griggs_v._duke_power_company.docx

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Landmark Court Cases

Laws passed by Congress are usually broad in nature and are refined when applied to specific situations. Furthermore, the general nature of the equal employment laws both allowed and caused enforcement agencies such as the EEOC to develop guidelines and enforce the acts as they interpreted them. Unfortunately, employers were often confused about the guidelines and enforcement of equal employment laws by the EEOC and OFCCP. The confusion and anger that resulted have led to many lawsuits concerning the interpretation of equal opportunity laws and guidelines. Again unfortunately, many court decisions have been not only confusing but, in some instances, apparently conflicting.

Nevertheless, several Supreme Court decisions have provided guidance for interpreting equal employment opportunity laws. Some of the more important decisions are described in the following sections.

Griggs v. Duke Power Company 4

The Griggs case concerned the promotion and transfer policies of the Duke Power company at its Dan River Steam Station. Duke permitted incumbent employees who lacked a high school education to transfer from an “outside” job to an “inside” job by passing two tests: the Wonderlic Personnel Test, which purports to measure general verbal facility, and the Bennett Mechanical Aptitude Test. The passing scores approximated the national median for high school graduates.

Web site: National Employment Lawyers Association www.nela.org

In a class action suit, African American employees argued that these practices violated Title VII, since neither having a high school education nor passing the tests was necessary for successful performance on the jobs in question. The suit also argued that the practices were illegal because a much higher percentage of African Americans did not have high school educations. The company argued that the requirements were based on the company's judgment that they would generally improve the overall quality of the workforce and that the company had no discriminatory intent in instituting the requirements. The company argued that its lack of discriminatory intent was demonstrated by its efforts to help undereducated employees through financing two-thirds of the cost of tuition for high school education.

In 1971, the Supreme Court ruled in favor of the African American employees. The decision established several significant points concerning equal employment opportunity:

(1) The consequences of employment practices, not simply the intent or motivation of the employer, are the thrust of Title VII in that practices that discriminate against one group more than another or continue past patterns of discrimination are illegal regardless of the nondiscriminatory intent of the employer; (2) the disparate impact doctrine provides that when the plaintiff shows that an employment practice disproportionately excludes groups protected by Title VII, the burden of proof shifts to the defendant to prove that the standard reasonably relates to job performance; and (3) the EEOC's guidelines that permitted the use of only job-related tests are appropriate.