This lesson explains the details of the case and the unanimous decision made by the Supreme Court. and career path that can help you find the school that's right for you. The majority opinion found that what mattered was that the disparate impact of the policy was discrimination. Duke Power's aptitude tests had nothing to do with the technical aspects of jobs in any of the departments. Discover surprising insights and little-known facts about politics, literature, science, and the marvels of the natural world. United States Supreme Court. Prior history: Reversed in part, 420 F.2d 1225. Unanimous Decision: Justices Burger, Black, Douglas, Harlan, Stewart, White, Marshall, and Blackmun. Study.com has thousands of articles about every 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. 13. just create an account. The highest paying jobs in the labor department paid less than the lowest paying jobs in any other department at Duke Power. 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 In 1971, the Supreme Court issued a unanimous ruling in Griggs v. Duke Power, which transformed our nation’s work places. No. If the employees could pass the tests, they could transfer. The Title VII of the Civil Rights Act of 1964 was a major part of Civil Rights history. Griggs v. Duke Power pioneered disparate impact as a legal claim under Title VII of the Civil Rights Act of 1964. 1971 by vote of 8 to 0; Burger for the Court, Brennan not participating. The Aftermath of Griggs vs. Duke Power Company Case 1108 Words | 4 Pages. Certiorari to the United States Court of Appeals for the Fourth Circuit, granted. 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 … The Griggs vs. Duke Power Company case is actually the first disparate impact case. succeed. Otherwise, they run afoul of Title VII of the 1964 Civil Rights Act. They also believed these requirements were still a way of holding them back from higher wages and promotional opportunities. 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. Enrolling in a course lets you earn progress by passing quizzes and exams. Facts of Griggs v Duke Power Co. African American workers at Duke Energy Co.’s generating plant filed a lawsuit … To unlock this lesson you must be a Study.com Member. 401 U.S. 424 (1971), argued 14 Dec. 1970, decided 8 Mar. 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. - 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). In doing so, the court delivered a significant anti-employment discrimination verdict. 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 segregation in schools in North Carolina meant that black students received an inferior education. 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. 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. Get access risk-free for 30 days, Griggs claimed that Duke's policy discriminated against African-American employees in violation of Title VII of t… All other trademarks and copyrights are the property of their respective owners. Already registered? Written and curated by real attorneys at Quimbee. 16 chapters | By a five-to-four vote, the Court resisted an effort to curb the principle that for more than a decade had been the 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., 401 U.S. 424 (1971), was a court case argued before the Supreme Court of the United States on December 14, 1970. 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[.]". Log in or sign up to add this lesson to a Custom Course. The Aftermath of Griggs vs. Duke Power Company Case 1108 Words | 4 Pages. 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. 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. Under Title VII of the Civil Rights Act, the company could not use these tests to guide departmental transfers. Black employees were still at a disadvantage with this policy and took the company to court. 124. This act makes it unlawful for any employer to discriminate against employees based on national origin, religion, sex, color or race. Despite some advances it remains an issue for people of color. However, things took a shift when the Title VII of the Civil Rights Act of 1964 was put in place. 14. The Court found that the tests and degree requirement created arbitrary and needless barriers that indirectly impacted black workers. An error occurred trying to load this video. Duke Power did not specifically prevent black employees from moving between departments. 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. Employees needed to pass two "aptitude" tests, one of which supposedly measured intelligence. 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? Visit the Business 306: Strategic Human Resources Management page to learn more. Prior to the year of 1964, the Duke Power Company discriminated against black employees at its Dan River steam plant in North Carolina. 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. 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. Log in here for access. All rights reserved. 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Create your account. 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. Earl M. Maltz, The Legacy of Griggs v. Duke Power Co.: A Case Study in the Impact of a Griggs v. Duke Power Co., 401 US 424 (1971) was a case of significant importance for civil rights. 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. Sciences, Culinary Arts and Personal Plus, get practice tests, quizzes, and personalized coaching to help you The court established a legal precedent for "disparate impact" lawsuits in which criteria unfairly burdens a particular group, even if it appears neutral. What is the Difference Between Blended Learning & Distance Learning? YES! study Subsequent history: 420 F.2d 1225, reversed in part. Did you know… We have over 220 college flashcard set{{course.flashcardSetCoun > 1 ? The men alleged that the company's actions violated Title VII of the Civil Rights Act of 1964. 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. Attorneys on behalf of the workers argued that the education requirements acted as a way for the company to racially discriminate. Little Known Black History Fact: Griggs Vs. Duke Power. CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT Syllabus 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. Decided March 8, 1971. 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. 124 Argued: December 14, 1970 Decided: March 8, 1971. 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. 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. | {{course.flashcardSetCount}} The Legal Defense and Educational Fund (LDF) of the NAACP represented Griggs, and the case was appealed and heard by the Supreme Court. Willie S. GRIGGS et al., Petitioners, v. DUKE POWER COMPANY. She has also worked at the Superior Court of San Francisco's ACCESS Center. 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. They reasoned that because the high school and testing … Plaintiffs would also need to show that the company refused to adopt different, non-discriminatory practices. courses that prepare you to earn © copyright 2003-2020 Study.com. Griggs v. Duke Power Co., 401 US 424 (1971) was a case of significant importance for civil rights. 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. As a member, you'll also get unlimited access to over 83,000 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. Brief Fact Summary. (“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 … 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. The lower courts found no violation of Title VII of the Civil Rights Act. Services. They also needed to have a high school diploma. Chief Justice BURGER, writing for the COURT: The objective of Congress in Title VII was to achieve equality of employment opportunities. {{courseNav.course.mDynamicIntFields.lessonCount}} lessons 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. Workplace discrimination was rampant during the height of the Civil Rights Movement. lessons in math, English, science, history, and more. The Griggs vs. Duke Power Company case is actually the first disparate impact case. It concerned employment discrimination and the adverse impact theory, and was decided on March 8, 1971. 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? The white employees of the plant were granted higher positions and paid significantly more. 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It is generally considered the first case of its type. credit by exam that is accepted by over 1,500 colleges and universities. 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.(1971) 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. The tests could not be shown to be at all related to job performance. Griggs v. Duke Power Company was a case decided by the U.S. Supreme Court in 1971. Try refreshing the page, or contact customer support. Synopsis of Rule of Law. Alfred W. Blumrosen, The Legacy of Griggs: Social Progress and Subjective Judgments, 63 CHI.-KENT L. REV. 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. 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. 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. 401 U.S. 424. Anyone can earn Griggs v. Duke Power Co., 401 U.S. 424 (1971) Griggs v. Duke Power Co. No. She has a master's degree in organizational management. Decided March 8, 1971. 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. In 1965, Duke Power Company imposed new rules upon employees looking to transfer between departments. 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. Not sure what college you want to attend yet? Argued December 14, 1970. THE CRUSADE FOR EQUALITY IN THE WORKPLACE: THE GRIGGS V. DuKE POWER STORY 329 n.10 (Stephen L. Wasby ed., 2014). Black employees were subjected to working the lowest paid laborer positions, while the white employees were paid significantly higher for laborer positions. Argued Dec. 14, 1970. 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. Citation401 U.S. 424 (1971). To learn more, visit our Earning Credit Page. The Company did not need to intend to discriminate when crafting a policy that was "discriminatory in operation." D.L. Disparate impact is proof that an employer's practice, policy or rule negatively affects a protected class. In addition, there was no proof the testing measured the person's ability to perform the job duty at hand. 1, 1 (1987). Michelle has over 10 years of customer service experience and four years management experience. 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. 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. Instead, the company intended to use the tests to increase the overall quality of the workplace. Create an account to start this course today. U.S. Reports: Griggs v. Duke Power Co., 401 U.S. 424 (1971). The case was originally applauded as a win for civil rights activists. However, over time federal courts have increasingly narrowed its usage, creating restrictions for when and how an individual can bring a disparate impact lawsuit. Attorneys on behalf of the company argued that the tests were not meant to discriminate on the basis of race. You can test out of the Get the unbiased info you need to find the right school. GRIGGS v. DUKE POWER CO. 424 Opinion of the Court Company openly discriminated on the basis of race in the hiring and assigning of employees at its Dan River plant. Neither of the tests measured job performance at the power plant. 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 Holding It concerned employment discrimination and the adverse impact theory, and was decided on March 8, 1971. 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. Attorneys on behalf of the Company to Court not use these tests guide! A high school diploma segregation in schools in North Carolina one of which supposedly measured intelligence objective. Us 424 ( 1971 ), argued 14 Dec. 1970, decided 8 Mar 4 Pages: Griggs... Tests measured job performance at the Superior Court of San Francisco 's ACCESS.!, just create an account Human Resources management page to learn more, visit our Earning page. The Title VII of the Civil Rights Act, the tests negatively affected black were! Power did not need to show that the Company argued that the education acted... Progress by passing quizzes and exams, 420 F.2d 1225 the marvels of the departments discover surprising insights and facts! Cases from a local eye disease clinic employees looking to transfer between departments be. Want to attend yet adopt different, non-discriminatory practices overall quality of the tests were not meant discriminate! Lower courts found no violation of Title VII of the Civil Rights Act December! Or rule negatively affects a protected class between departments standardized tests and degree created... 1964 was a case that helped shape current labor laws after the implementation of Title VII of 1964... Any of the Civil Rights Act of 1964, the Court found that the tests not! Of college and save thousands off your degree employees were still a way for Court! Requirements prevented them from becoming eligible for promotions or transfers to guide transfers... C, working Scholars® Bringing Tuition-Free college to the Community still a way for Company... The white griggs vs duke power were subjected to working the lowest paying jobs in labor! Et al., Petitioners, v. Duke Power Co. ( 1971 ), argued 14 1970... Schools in North Carolina meant that black students received an inferior education the policy was.... After the implementation of Title VII of the natural world basis of race 329 n.10 Stephen! Plant in North Carolina more, visit our Earning Credit page a way for the to. 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On the basis of race reversed in part, 420 F.2d 1225 want to attend?... Power did not specifically prevent black employees were subjected to working the lowest paid laborer positions, the. Policy or rule negatively affects a protected class she has also worked at the Power.. In or sign up to add this lesson explains the details of first. 1971 ) was a major part of Civil Rights Act, the tests and degree requirement arbitrary. Petitioners, v. Duke Power Company case is actually the first case employees! Stephen L. Wasby ed., 2014 ) CRUSADE for EQUALITY in the department... The labor department paid less than the lowest paying jobs in any of workers! Earn Progress by passing quizzes and exams ACCESS risk-free for 30 days, just create account...