Washington v. Davis
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| Washington v. Davis | |||||||||||||||
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| Argued March 1, 1976 Decided June 7, 1976 |
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| Holding | |||||||||||||||
| Racial discrimination by the state must contain two elements: a racially disproportionate impact and discriminatory motivation on the part of the state actor. | |||||||||||||||
| Court membership | |||||||||||||||
| Chief Justice: Warren E. Burger Associate Justices: William J. Brennan, Potter Stewart, Byron White, Thurgood Marshall, Harry Blackmun, Lewis Franklin Powell, Jr., William Rehnquist, John Paul Stevens |
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| Case opinions | |||||||||||||||
| Majority by: White Joined by: Burger, Blackmun, Powell, Rehnquist, Stevens; Stewart (parts I and II only) Concurrence by: Stevens Dissent by: Brennan Joined by: Marshall |
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| Laws applied | |||||||||||||||
| U.S. Const. amend. V; Civil Rights Act of 1964 | |||||||||||||||
Washington v. Davis, 426 U.S. 229 (1976), was a United States Supreme Court case regarding the application of the Equal Protection Clause. Two African Americans had applied for positions in the Washington, DC police department, and sued after being turned down. They claimed that the department used racially discriminatory hiring procedures, by implementing a test of verbal skills (Test 21), which was failed disproportionally by African Americans. The Court ruled against them, finding that use of the test did not violate the Equal Protection Clause.
The important general rule created by Washington v. Davis is that under the Equal Protection Clause of the Fourteenth Amendment, "[an] official action will not be held unconstitutional solely because it results in a racially disproportionate impact." Instead, a plaintiff must prove discriminatory motive on the state actor's part. The court noted that "disproportionate impact is not irrelevant, but it is not the sole touchstone of an invidious racial discrimination forbidden by the Constitution". The purpose-based standard elucidated in the Court's 1976 opinion has made it much more difficult for plaintiffs to prevail in discrimination suits.
Justice Byron White wrote the opinion for the majority. Justice John Paul Stevens wrote a concurring opinion, while Justices William Brennan and Thurgood Marshall dissented.
[edit] Rationale of The Court
The court reversed the decision of the D.C. Court of Appeals on grounds that while it may have been true that Test 21 had the effect of removing a greater number of black than white applicants, the test did not have a discriminatory purpose. The Court found that the Court of Appeals had erroneously assumed that the stricter, effect-based standard of Title VII of the Civil Rights Act of 1964 also applied to the constitutional Equal Protection Clause.
As the Court of Appeals understood Title VII, employees or applicants proceeding under it need not concern themselves with the employer's possibly discriminatory purpose but instead may focus solely on the racially differential impact of the challenged hiring or promotion practices. This is not the constitutional rule. We have never held that the constitutional standard for adjudicating claims of invidious racial discrimination is identical to the standards applicable under Title VII, and we decline to do so today. - J. White, 426 U.S. 229 at 238.
To further its argument that Test 21 did not have a discriminatory purpose, the Court discussed evidence that the Washington D.C. police department had gone to significant lengths to recruit black officers. Moreover, the Court noted that in the years since the case was brought before the trial court, the ratio of blacks on the police force to blacks in the community had nearly evened out.
Nor on the facts of the case before us would the disproportionate impact of Test 21 warrant the conclusion that it is a purposeful device to discriminate against Negroes and hence an infringement of the constitutional rights of respondents as well as other black applicants. As we have said, the test is neutral on its face and rationally may be said to serve a purpose the Government is constitutionally empowered to pursue. Even agreeing with the District Court that the differential racial effect of Test 21 called for further inquiry, we think the District Court correctly held that the affirmative efforts of the Metropolitan Police Department to recruit black officers, the changing racial composition of the recruit classes and of the force in general, and the relationship of the test to the training program negated any inference that the Department discriminated on the basis of race or that "a police officer qualifies on the color of his skin rather than ability. - J. White, 426 U.S. 229 at 246.
