You are selecting keratitis cases from a local eye disease clinic. The men alleged that the company's actions violated Title VII of the Civil Rights Act of 1964. In the groundbreaking decision Griggs v. Duke Power (1971), the United States Supreme Court ruled in favor of the plaintiffs, finding such employment practices violated Title 7 of the Civil Rights Act of 1964 when they disparately affected minorities. 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. Try refreshing the page, or contact customer support. While the Civil Rights Act was a major stepping stone to end employee discrimination, black employees at the Duke Power Company still did not believe they were being treated equally as their white co-workers. To unlock this lesson you must be a Study.com Member. 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. credit by exam that is accepted by over 1,500 colleges and universities. The plant was organized into five operating de-partments: (1) Labor, (2) Coal Handling, (3) Opera-tions, (4) Maintenance, and (5) Laboratory and Test. The tests could not be shown to be at all related to job performance. The Supreme Court in turn, reversed the District Court's decision and ruled in favor of Griggs. Discover surprising insights and little-known facts about politics, literature, science, and the marvels of the natural world. 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. The majority opinion found that what mattered was that the disparate impact of the policy was discrimination. Already registered? Chief Justice Berger delivered the unanimous decision. study 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. Washington v. Davis: Supreme Court Case, Arguments, Impact, Guinn v. United States: A First Step to Voter Rights for Black Americans, How to Respond to Discrimination During a Job Interview, The Civil Rights Act of 1866: History and Impact, How Women Became Part of the 1964 Civil Rights Act, Shelby County v. Holder: Supreme Court Case, Arguments, Impact, Biography of Ruth Bader Ginsburg, Supreme Court Justice, Katzenbach v. Morgan: Supreme Court Case, Arguments, Impact, Title VII Laws on Harassment and Employment Discrimination. She has a master's degree in organizational management. In doing so, the court delivered a significant anti-employment discrimination verdict. Employees needed to pass two "aptitude" tests, one of which supposedly measured intelligence. All rights reserved. Michelle has over 10 years of customer service experience and four years management experience. Decided March 8, 1971. Citation401 U.S. 424 (1971). 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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. Anyone can earn It concerned employment discrimination and the adverse impact theory, and was decided on March 8, 1971. In 1965, Duke Power Company imposed new rules upon employees looking to transfer between departments. Brief Fact Summary. They reasoned that because the high school and testing … In addition, there was no proof the testing measured the person's ability to perform the job duty at hand. Plus, get practice tests, quizzes, and personalized coaching to help you 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. The Griggs vs. Duke Power Company case is actually the first disparate impact case. It is generally considered the first case of its type. Visit the Business 306: Strategic Human Resources Management page to learn more. Log in or sign up to add this lesson to a Custom Course. 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 … 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? Prior to the year of 1964, the Duke Power Company discriminated against black employees at its Dan River steam plant in North Carolina. Therefore, the tests negatively affected black employees seeking to work in higher positions. U.S. Reports: Griggs v. Duke Power Co., 401 U.S. 424 (1971). 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. | 10 401 U.S. 424. The court established a legal precedent for "disparate impact" lawsuits in which criteria unfairly burdens a particular group, even if it appears neutral. Get the unbiased info you need to find the right school. The Court found that the tests and degree requirement created arbitrary and needless barriers that indirectly impacted black workers. Alfred W. Blumrosen, The Legacy of Griggs: Social Progress and Subjective Judgments, 63 CHI.-KENT L. REV. Little Known Black History Fact: Griggs Vs. Duke Power. 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 Co., 401 U.S. 424 (1971) 1) Reference Details Jurisdiction: United States of America, the United States Court of Appeal for the Fourth Circuit Date of Decision: 8 March 1971 Case Status: Concluded Link to full case: Griggs vs. Duke Power Co. (1971) was a case that helped shape current labor laws after the implementation of Title VII. lessons in math, English, science, history, and more. When the case was presented to the District Court, the court ruled in favor of Duke Power Company because Griggs was unable to prove the testing and diploma requirement was actually discriminatory. Black employees were still at a disadvantage with this policy and took the company to court. Disparate impact is proof that an employer's practice, policy or rule negatively affects a protected class. You can test out of the Griggs v. Duke Power Co. Quick Reference. Griggs v. Duke Power Co., 401 US 424 (1971) was a case of significant importance for civil rights. Following the decision of Griggs v.; Duke Power Company, the first court case to assess affirmative action in employment that made it to the Supreme Court in 1971, states took action to limit the application of affirmative action programs in their jurisdictions. Written and curated by real attorneys at Quimbee. 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. just create an account. YES! 124. The Griggs vs. Duke Power Company case is actually the first disparate impact case. Study.com has thousands of articles about every 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. 14. Griggs v. Duke Power Co., 401 U.S. 424 (1971) Griggs v. Duke Power Co. No. 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. Earl M. Maltz, The Legacy of Griggs v. Duke Power Co.: A Case Study in the Impact of a v. Duke Power Co. Holding She has also worked at the Superior Court of San Francisco's ACCESS Center. 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. 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. The Supreme Court, led by Chief Justice Warren Burger, ruled that testing is a fair practice if done correctly to qualify the best candidates, but the operation of the testing in this instance was discriminatory. GRIGGS v. DUKE POWER CO.(1971) No. courses that prepare you to earn Decided March 8, 1971. flashcard sets, {{courseNav.course.topics.length}} chapters | Unanimous Decision: Justices Burger, Black, Douglas, Harlan, Stewart, White, Marshall, and Blackmun. THE CRUSADE FOR EQUALITY IN THE WORKPLACE: THE GRIGGS V. DuKE POWER STORY 329 n.10 (Stephen L. Wasby ed., 2014). 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. 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. An analysis and presentation of the Griggs vs Duke Power Co. equal employment opportunity and personnel case. Services. Griggs v. Duke Power Company was a case decided by the U.S. Supreme Court in 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. 124 Argued: December 14, 1970 Decided: March 8, 1971. 401 U.S. 424 (1971), argued 14 Dec. 1970, decided 8 Mar. 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. 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. The court established a legal precedent for "disparate impact" lawsuits in which criteria unfairly burdens a particular group, even if it appears neutral. 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. 13. 1971 by vote of 8 to 0; Burger for the Court, Brennan not participating. 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. Key Questions: Did Duke Power Company's intradepartmental transfer policy, requiring a high school education and the achievement of minimum scores on two separate aptitude tests, violate Title VII of the 1964 Civil Rights Act? An error occurred trying to load this video. 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. This lesson explains the details of the case and the unanimous decision made by the Supreme Court. Did you know… We have over 220 college Despite some advances it remains an issue for people of color. As a result, the company could not claim that the Civil Rights Act allowed the use of their tests. and career path that can help you find the school that's right for you. Griggs v. Duke Power Company is a historical case of employees who took a stand against workplace discrimination. Griggs (Plaintiff) was an African American employee of Duke Power Co. (Defendant) who challenged Defendant’s job requirements as a violation of Title VII of the Civil Rights Act because they disparately impacted African American applicants and were not tied to job performance. Log in here for access. To learn more, visit our Earning Credit Page. Earn Transferable Credit & Get your Degree, McDonnell Douglas Corp. v. Green: History & Analysis, Introduction to Human Resource Management: Certificate Program, Organizational Behavior Syllabus Resource & Lesson Plans, Senior Professional in Human Resources - International (SPHRi): Exam Prep & Study Guide, PHR Certification Exam Study Guide - Professional in Human Resources, Psychology 107: Life Span Developmental Psychology, SAT Subject Test US History: Practice and Study Guide, SAT Subject Test World History: Practice and Study Guide, Geography 101: Human & Cultural Geography, Sociology 103: Foundations of Gerontology, Criminal Justice 101: Intro to Criminal Justice, Political Science 101: Intro to Political Science. Griggs v. Duke Power Co., 401 U.S. 424, was a court case argued before the Supreme Court of the United States on December 14, 1970. 1, 1 (1987). Griggs v. Duke Power: Implications for College Credentialing Bryan O’Keefe and Richard Vedder This paper will describe Griggs, the environment from which it emerged, and the subsequent judicial and political activity that created such great constraints on testing. 's' : ''}}. Under Title VII of the Civil Rights Act, the company could not use these tests to guide departmental transfers. credit-by-exam regardless of age or education level. Attorneys on behalf of the company argued that the tests were not meant to discriminate on the basis of race. Of the 14 black men working in the labor department at Duke Power's Dan River Steam Station, 13 of them signed onto a lawsuit against the company. 124. succeed. What is the Difference Between Blended Learning & Distance Learning? However, things took a shift when the Title VII of the Civil Rights Act of 1964 was put in place. It is generally considered the first case of its type. Create an account to start this course today. © copyright 2003-2020 Study.com. {{courseNav.course.mDynamicIntFields.lessonCount}} lessons United States Supreme Court. The case was originally applauded as a win for civil rights activists. flashcard set{{course.flashcardSetCoun > 1 ? The Aftermath of Griggs vs. Duke Power Company Case 1108 Words | 4 Pages. Also, the District Court believed the tests were related to the job skill requirements. 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. first two years of college and save thousands off your degree. If the employees could pass the tests, they could transfer. Black employees believed the requirement of a high school diploma and passing the intelligence tests was unfair because the majority of black employees didn't have a high school education, nor were they capable of passing the tests at the rate of the white employees. Argued Dec. 14, 1970. The Legal Defense and Educational Fund (LDF) of the NAACP represented Griggs, and the case was appealed and heard by the Supreme Court. 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. 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. 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. (“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 … Plaintiffs would also need to show that the company refused to adopt different, non-discriminatory practices. Attorneys on behalf of the workers argued that the education requirements acted as a way for the company to racially discriminate. imaginable degree, area of Prior to Title VII, black employees could not work in four of the five departments at Duke nor could they achieve the same wage as a white employee. CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT Syllabus - Definition, Types, Symptoms & Treatment, How to Prep for the NYS Spanish Regents Exam, Study.com Demo for Workforce College Accelerator, Tech and Engineering - Questions & Answers, Health and Medicine - Questions & Answers, You are conducting a case-control study to examine the association between lifetime contact lens use and cases of keratitis (a serious eye disease). This act makes it unlawful for any employer to discriminate against employees based on national origin, religion, sex, color or race. 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. It will discuss testing today and then provide economic information The Aftermath of Griggs vs. Duke Power Company Case 1108 Words | 4 Pages. 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. Otherwise, they run afoul of Title VII of the 1964 Civil Rights Act. 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Neither of the tests measured job performance at the power plant. It concerned employment discrimination and the adverse impact theory, and was decided on March 8, 1971. Elianna Spitzer is a legal studies writer and a former Schuster Institute for Investigative Journalism research assistant. The Title VII of the Civil Rights Act of 1964 was a major part of Civil Rights history. No. However, over time federal courts have increasingly narrowed its usage, creating restrictions for when and how an individual can bring a disparate impact lawsuit. 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 Instead, the company intended to use the tests to increase the overall quality of the workplace. All other trademarks and copyrights are the property of their respective owners. As a member, you'll also get unlimited access to over 83,000 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. 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. Standardized tests and degree requirements prevented them from becoming eligible for promotions or transfers. Willie S. GRIGGS et al., Petitioners, v. DUKE POWER COMPANY. Griggs v. Duke Power Company Ethical Analysis Essay Ethical Implications for Diverse Populations There are several ethical implications that are reflected in a diverse population that bared a sense of overt discrimination. Griggs v. Duke Power Co., 401 US 424 (1971) was a case of significant importance for civil rights. Subsequent history: 420 F.2d 1225, reversed in part. Griggs claimed that Duke's policy discriminated against African-American employees in violation of Title VII of t… | {{course.flashcardSetCount}} Sciences, Culinary Arts and Personal Which of the following would be ideal c, Working Scholars® Bringing Tuition-Free College to the Community. Facts of Griggs v Duke Power Co. African American workers at Duke Energy Co.’s generating plant filed a lawsuit … The court ruled unanimously against the intelligence testing practices of the Duke Power Company. By a five-to-four vote, the Court resisted an effort to curb the principle that for more than a decade had been the Duke Power's aptitude tests had nothing to do with the technical aspects of jobs in any of the departments. 134 lessons D.L. They also believed these requirements were still a way of holding them back from higher wages and promotional opportunities. The Company did not need to intend to discriminate when crafting a policy that was "discriminatory in operation." Workplace discrimination was rampant during the height of the Civil Rights Movement. Willie Griggs filed a class action, on behalf of several fellow African- American employees, against his employer Duke Power Company . Examples of Griggs v. Duke Power Company in the following topics: State Initiatives Against Affirmative Action. Create your account. 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? They also needed to have a high school diploma. 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. 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.” Duke Power did not specifically prevent black employees from moving between departments. The highest paying jobs in the labor department paid less than the lowest paying jobs in any other department at Duke Power. Chandler. 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 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. Sociology 110: Cultural Studies & Diversity in the U.S. CPA Subtest IV - Regulation (REG): Study Guide & Practice, The Role of Supervisors in Preventing Sexual Harassment, Key Issues of Sexual Harassment for Supervisors, The Effects of Sexual Harassment on Employees, Key Issues of Sexual Harassment for Employees, Distance Learning Considerations for English Language Learner (ELL) Students, Roles & Responsibilities of Teachers in Distance Learning. 16 chapters | Griggs v. Duke Power pioneered disparate impact as a legal claim under Title VII of the Civil Rights Act of 1964. Synopsis of Rule of Law. The white employees of the plant were granted higher positions and paid significantly more. In Griggs v Duke Power Co, 401 U.S. 424 (1971), the U.S. Supreme Court held that aptitude tests used by employers that disparately impact ethnic minority groups must be reasonably related to the job. Enrolling in a course lets you earn progress by passing quizzes and exams. Certiorari to the United States Court of Appeals for the Fourth Circuit, granted. 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[.]". 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. Year of 1964 was put in place and a former Schuster Institute for Investigative Journalism research.! Several fellow African- American employees, against his employer Duke Power pioneered disparate impact of the policy was discrimination equal... The technical aspects of jobs in the workplace attend yet STORY 329 n.10 ( Stephen L. Wasby ed. 2014. Prevent black employees seeking to work in higher positions and paid significantly more becoming eligible for promotions or.... Other department at Duke Power Company discriminated against black employees were still a... The objective of Congress in Title VII there was no proof the testing measured the 's! Vs. Duke Power pioneered disparate impact of the Civil Rights c, working Bringing... Work places and degree requirements prevented them from becoming eligible for promotions or transfers of! Plaintiffs would also need to intend to discriminate when crafting a policy was! To intend to discriminate on the basis of race for the Court found that what mattered that... 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