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Supreme Court of the United States - 426 U.S. 229
This case involves a personnel test, Test 21, used by the District of Columbia Metropolitan Police Department for police officer positions. African American police officers filed a lawsuit alleging racial discrimination in the Department's promotion policies. Two other African American applicants intervened, claiming that the recruiting procedures, including Test 21, discriminated against black applicants. The Court of Appeals invalidated Test 21, citing its disproportionate impact on black candidates. The Supreme Court reversed the decision, finding that the test was not unlawfully discriminatory and did not violate the due process clause of the Fifth Amendment. The Court clarified that a racially disproportionate impact does not make an official act unconstitutional unless it reflects a racially discriminatory purpose. To prove intentional discrimination, a purpose to discriminate must be present. The principle of equal protection requires intentional state action resulting in a current condition of segregation for de jure segregation, while de facto segregation does not involve intentional segregation. The court found that it was an error to grant summary judgment for the respondents based on the Fifth Amendment and that the Court of Appeals should have affirmed the judgment of the District Court granting the motions for summary judgment filed by the petitioners and federal parties. The respondents were not entitled to relief on either constitutional or statutory grounds.
Justice Stevens agrees with the Court's decision but adds comments on the constitutional and statutory issues discussed in the opinion. He notes that purposeful discrimination is a common thread in cases involving criminal convictions, reapportionment, school desegregation, and unequal administration of ordinances. The most reliable evidence of intent is often objective evidence of what actually happened, rather than evidence of the actor's subjective state of mind. The distinction between discriminatory purpose and discriminatory impact is not always clear or critical, and a constitutional issue may not arise every time a disproportionate impact is shown. However, in cases where the disproportion is significant, the standard of purpose or effect may not matter.
The dissenting opinion disagrees with the Court's decision that Test 21, a job qualification examination given by the District of Columbia Metropolitan Police Department, does not unlawfully discriminate on the basis of race under constitutional or statutory standards. The Court found Test 21 as job-related under 5 U.S.C. § 3304, but it may not necessarily be considered job-related under Title VII. The Court's analysis of the provision is irrelevant since the respondents did not make a claim under § 3304. The Court's conclusion is in conflict with Griggs and Albemarle, which held that if an employment practice that excludes a protected group cannot be shown to be related to job performance, it is prohibited. The Court found that the petitioners failed to demonstrate a correlation between Test 21 scores and job performance, and their validity study was unable to discern a significant positive relationship between training averages and job performance.
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