If the employees could pass the tests, they could transfer. Griggs v. Duke Power Company 401 U.S. 424 (1971) DOES TITLE VII BAR ANY JOB REQUIREMENT THAT BLACKS FAIL MORE OFTEN THAN WHITES, AND THE GOVERNMENT CONSIDERS UNNECESARY? It concerned the legality, under Title VII of the Civil Rights Act of 1964, of high school diplomas and intelligence test scores as prerequisites for employment. flashcard set{{course.flashcardSetCoun > 1 ? first two years of college and save thousands off your degree. Get Griggs v. Duke Power Co., 401 U.S. 424 (1971), United States Supreme Court, case facts, key issues, and holdings and reasonings online today. In Griggs v. Duke Power (1971), the Supreme Court ruled that, under Title VII of the 1964 Civil Rights Act, tests measuring intelligence could not be used in hiring and firing decisions. Griggs v. Duke Power Co., case in which the U.S. Supreme Court, in a unanimous decision on March 8, 1971, established the legal precedent for so-called “ disparate-impact” lawsuits involving instances of racial discrimination. Get the unbiased info you need to find the right school. YES! Under Title VII of the Civil Rights Act of 1964, an employer involved in interstate commerce cannot: Under Title VII of the Civil Rights Act, can an employer require an employee to graduate high school, or pass standardized tests that are unrelated to job performance? 401 U.S. 424. courses that prepare you to earn © copyright 2003-2020 Study.com. just create an account. 124 Argued: December 14, 1970 Decided: March 8, 1971. Case Summary of Griggs v. Duke Power Co.: A group of African-American employees sued their employer, Duke Power Company, for a policy that mandated a high school diploma and satisfactory scores on two general aptitude tests in order to advance in the company. Testing employees for a job is fair, but what makes this case disparate impact is during this era blacks were known to have disadvantages with education, so the likelihood of having a high school diploma and being able to pass the intelligence tests were rare. Ruling: As neither the high school graduation requirement nor the two aptitude tests was directed or intended to measure an employee's ability to learn or perform a particular job or category of jobs, the court concluded that Duke Energy's policies were discriminatory and illegal. Despite some advances it remains an issue for people of color. The Griggs vs. Duke Power Company case is actually the first disparate impact case. | {{course.flashcardSetCount}} Citation401 U.S. 424 (1971). You can test out of the The court established a legal precedent for "disparate impact" lawsuits in which criteria unfairly burdens a particular group, even if it appears neutral. When the Civil Rights Act of 1964 went into effect, the Duke Power Company had a practice of only allowing black men to work in the labor department. Black employees at Duke Power Company prior to Title VII of the Civil Rights Act of 1964 were treated unfairly by being restricted to working as laborers. What is the Difference Between Blended Learning & Distance Learning? Certiorari to the United States Court of Appeals for the Fourth Circuit, granted. lessons in math, English, science, history, and more. Not sure what college you want to attend yet? According to the Court, while the section did allow for tests, the Equal Employment Opportunity Commission had clarified that the tests must be directly related to job performance. An employee by the name of Willie Griggs decided to file a lawsuit on behalf of himself and twelve other employees against Duke Power Company. 401 U.S. 424 (1971), argued 14 Dec. 1970, decided 8 Mar. imaginable degree, area of flashcard sets, {{courseNav.course.topics.length}} chapters | Prior history: Reversed in part, 420 F.2d 1225. The court ruled unanimously against the intelligence testing practices of the Duke Power Company. Griggs v. Duke Power Co., 401 US 424 (1971) was a case of significant importance for civil rights. Michelle has over 10 years of customer service experience and four years management experience. Also, the District Court believed the tests were related to the job skill requirements. Try refreshing the page, or contact customer support. Discover surprising insights and little-known facts about politics, literature, science, and the marvels of the natural world. The Supreme Court’s decision in Griggs v. Duke Power Company, 401 U.S. 424 (1971), addressed the Title VII issues created by employer policies that are facially neutral, but which adversely impact employees on the basis of race, sex, or religion. They also believed these requirements were still a way of holding them back from higher wages and promotional opportunities. Alfred W. Blumrosen, The Legacy of Griggs: Social Progress and Subjective Judgments, 63 CHI.-KENT L. REV. 124. The Aftermath of Griggs vs. Duke Power Company Case 1108 Words | 4 Pages. The court established a legal precedent for "disparate impact" lawsuits in which criteria unfairly burdens a particular group, even if it appears neutral. Title VII of the Civil Rights Act of 1964 made it unlawful for any employer to discriminate against employees based on national origin, religion, sex, color or race, as well as making it unlawful for an employer to retaliate against its employees for filing a discrimination charge, complaining about discrimination or even participating in a discrimination lawsuit. Duke Power's aptitude tests had nothing to do with the technical aspects of jobs in any of the departments. Griggs v. Duke Power Co. Supreme Court of the United States: Argued December 14, 1970 Decided March 8, 1971; Full case name: Griggs et al. and career path that can help you find the school that's right for you. The plant was organized into five operating de-partments: (1) Labor, (2) Coal Handling, (3) Opera-tions, (4) Maintenance, and (5) Laboratory and Test. As a result of LDF’s advocacy, the Supreme Court embraced a powerful legal tool – now known as the “disparate impact” framework – that has proved essential in the fight to eradicate arbitrary and artificial barriers to equal employment opportunity for all individuals, regardless of their race. The majority opinion found that what mattered was that the disparate impact of the policy was discrimination. Argued December 14, 1970. All other trademarks and copyrights are the property of their respective owners. It will discuss testing today and then provide economic information Duke Power Company argued that the tests were not in any form used to discriminate against its black employees and were actually a method to offer advancement opportunities outside of the labor department. Also under this act, it is unlawful for an employer to retaliate against its employees for filing a discrimination charge, complaining about discrimination or even participating in a discrimination lawsuit. This meant that the testing and diploma requirements negatively affected black employees because they were least likely to have the education requirements and ability to pass the tests. Griggs' claim was that the diploma requirements and the intelligence tests were used as an intent to discriminate against black employees and were against the Title VII of the Civil Rights Act of 1964. It is generally considered the first case of its type. 1971 by vote of 8 to 0; Burger for the Court, Brennan not participating. No. The District Court ruled in favor of Duke Power Company, but the Supreme Court then reversed the decision and indeed found the testing as a disparate impact, which is proof that an employer's practice, policy or rule negatively affects a protected class. In 1971, the Supreme Court issued a unanimous ruling in Griggs v. Duke Power, which transformed our nation’s work places. Duke Power did not specifically prevent black employees from moving between departments. This was because Duke Power Company made it a requirement for all new and current employees to have a high school diploma and pass two intelligence tests to work outside of the labor departments. Griggs is recognized as the most significant case in the development of employment discrimination law under Title VII of the Civil Rights Act of 1964. You are selecting keratitis cases from a local eye disease clinic. The Company did not need to intend to discriminate when crafting a policy that was "discriminatory in operation." Services. Employees needed to pass two "aptitude" tests, one of which supposedly measured intelligence. Griggs v. Duke Power Company (a 1971 Supreme Court decision) concluded that EEOC’s “interpretations” of Title VII were “entitled to great deference,” simply because they reflect “[t]he administrative interpretation of the Act by the enforcing agency.” Decided March 8, 1971. griggs v. DUKE POWER CO Negro employees at respondent's generating plant brought this action, pursuant to Title VII of the Civil Rights Act of 1964, challenging respondent's requirement of a high school diploma or passing of intelligence tests as a condition of employment in or transfer to jobs at the plant. However, things took a shift when the Title VII of the Civil Rights Act of 1964 was put in place. Enrolling in a course lets you earn progress by passing quizzes and exams. Griggs v. Duke Power Company is a historical case of employees who took a stand against workplace discrimination. The new Civil Rights exhibit will cover the 1971 Griggs vs. Duke Power Supreme Court Case, highlight its relevance to modern day movements and help to fill an educational gap in the way Civil Rights features in curriculums, which all too often neatly caps the … Visit the Business 306: Strategic Human Resources Management page to learn more. It concerned employment discrimination and the adverse impact theory, and was decided on March 8, 1971. 1, 1 (1987). Instead, the company intended to use the tests to increase the overall quality of the workplace. TO THE RULE OF GRIGGS V. DUKE POWER COMPANY James P. Scanlan* In Connecticut v. Teal1 the Supreme Court issued a ruling of major importance to the way the law defines employment dis­ crimination. Quiz & Worksheet - Griggs v. Duke Power Co. Over 83,000 lessons in all major subjects, {{courseNav.course.mDynamicIntFields.lessonCount}}, Workforce Analysis Considerations: Staffing & Planning, The Hiring Process: How Human Resource Managers Recruit and Hire Employees, Using Recruitment Events to Reach Candidates, Internal Recruitment: Definition, Methods & Process, External Recruitment: Advantages, Disadvantages & Methods, Technology in a Job Interview: Use & Trends, Abiding by HRM Laws Regarding Recruitment & Selection, HRM Case Study: Data Driven Hiring Process at Google, Business 306: Strategic Human Resources Management, Biological and Biomedical Argued Dec. 14, 1970. Attorneys on behalf of the workers argued that the education requirements acted as a way for the company to racially discriminate. (“Disparate impact” describes a situation in which adverse effects of criteria—such as those applied to candidates for employment or promotion—occur primarily among people … {{courseNav.course.mDynamicIntFields.lessonCount}} lessons Anyone can earn She has also worked at the Superior Court of San Francisco's ACCESS Center. The Supreme Court in turn, reversed the District Court's decision and ruled in favor of Griggs. The men alleged that the company's actions violated Title VII of the Civil Rights Act of 1964. In doing so, the court delivered a significant anti-employment discrimination verdict. 14. v. Duke Power Co. Select a subject to preview related courses: The reason why the testing was discriminatory is that it led to a higher rate of black employees in lower paid positions. The company also argued that the tests could be used under section 703h of the Civil Rights Act, which allows "any professionally developed ability test" that is not "designed, intended or used to discriminate because of race[.]". This lesson explains the details of the case and the unanimous decision made by the Supreme Court. Chandler. This case was the first to make sure that employer's testing requirements were utilized to qualify the person for the job and not to measure the person with discriminatory intent. Workplace discrimination was rampant during the height of the Civil Rights Movement. Little Known Black History Fact: Griggs Vs. Duke Power. Willie Griggs filed a class action, on behalf of several fellow African- American employees, against his employer Duke Power Company . Decided March 8, 1971. The lower courts found no violation of Title VII of the Civil Rights Act. In 1965, Duke Power Company imposed new rules upon employees looking to transfer between departments. THE CRUSADE FOR EQUALITY IN THE WORKPLACE: THE GRIGGS V. DuKE POWER STORY 329 n.10 (Stephen L. Wasby ed., 2014). U.S. Reports: Griggs v. Duke Power Co., 401 U.S. 424 (1971). After this was passed, Duke Power Company required a high school diploma and intelligence tests to obtain a position outside of the laborer positions. Griggs v. Duke Power pioneered disparate impact as a legal claim under Title VII of the Civil Rights Act of 1964. Griggs v. Duke Power Co., 401 U.S. 424 (1971), was a court case argued before the Supreme Court of the United States on December 14, 1970. 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Elianna Spitzer is a legal studies writer and a former Schuster Institute for Investigative Journalism research assistant. Griggs challenged Duke's \"inside\" transfer policy, requiring employees who want to work in all but the company's lowest paying Labor Department to register a minimum score on two separate aptitude tests in addition to having a high school education. Facts of Griggs v Duke Power Co. African American workers at Duke Energy Co.’s generating plant filed a lawsuit … In Ward’s Cove Packing Co., Inc. v. Antonio (1989), for example, the Supreme Court gave plaintiffs the burden of proof in a disparate impact lawsuit, requiring that they show specific business practices and their impact. Therefore, the tests negatively affected black employees seeking to work in higher positions. Study.com has thousands of articles about every How Grandfather Clauses Disenfranchised Black Voters in the U.S. Take negative employment action (failing to hire, choosing to fire, or discriminating) against an individual because of the individual's race, color, religion, sex, or national origin; Limit, segregate or classify employees in a way that negatively impacts their employment opportunities because of their race, color, religion, sex, or national origin. Did you know… We have over 220 college 16 chapters | Create an account to start this course today. In terms of the importance of degrees or standardized tests, Chief Justice Berger noted: The Court addressed Duke Power's argument that section 703h of the Civil Rights Act allowed for ability tests in the majority opinion. With the technical aspects of jobs in the labor department paid less than the lowest paid laborer positions,! 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