Hazelwood School District v. United States

PETITIONER: Hazelwood School District; C. O. McDonald, Superintendent; Robert Bischof, Robert Coleman, Dorothy Smith, Charles Sweeney, Donald Mattox and Milton Strauss, Members of the Board of Education of the Hazelwood School District
RESPONDENT: United States
LOCATION: Hazelwood School District

DOCKET NO.: 76-255
DECIDED BY: Burger Court (1975-1981)
LOWER COURT: United States Court of Appeals for the Eighth Circuit

CITATION: 433 US 299 (1977)
ARGUED: Apr 27, 1977
DECIDED: Jun 27, 1977
GRANTED: Jan 10, 1977

ADVOCATES:
Lawrence G. Wallace - for United States
William H. Allen - for petitioners

Facts of the case

The U.S. Attorney General sued Hazelwood School District, alleging a “pattern or practice” of discrimination against African Americans in hiring teachers. This violated Title VII of the Civil Rights Act of 1964. The government provided statistical evidence of the number of African American teachers hired. The district court entered summary judgment for Hazelwood, finding that the government’s evidence did not establish a pattern or practice of discrimination. The court compared the number of African American teachers hired to the number of African American students in the school district. The U.S. Court of Appeals for the Eighth Circuit reversed, holding that the proper statistical comparison is between the number of African American teachers on staff and the number of qualified African American individuals in the relevant labor market. The relevant labor market included St. Louis and the county where Hazelwood was located.

Question

Does congress have the authority to prohibit racial discrimination under Title VII absent proof that a governmental agency purposely discriminated on the basis of race?

Can a court rely on statistical evidence to find prima facie case of race discrimination?

Media for Hazelwood School District v. United States

Audio Transcription for Oral Argument - April 27, 1977 in Hazelwood School District v. United States

Audio Transcription for Opinion Announcement - June 27, 1977 in Hazelwood School District v. United States

Warren E. Burger:

The judgments and opinion of the Court in 76-255, Hazelwood School District against the United States will be announced by Mr. Justice Stewart.

Potter Stewart:

This case comes to us on a writ of certiorari to United States Court of Appeals for the Eighth Circuit.

The litigation began in 1973 when the United States filed suit charging the Hazelwood School District in suburban St. Louis County, Missouri with having engaged in a pattern or practice of racial discrimination in the employment of its teachers in violation of Title VII of the Civil Rights Act of 1964 as amended.

The District Court found that Hazelwood had not engaged in such discrimination.

An important part of the District Court's reasoning was based on its view that the small number of Negroes employed by Hazelwood as teachers was of no value in proving that Hazelwood had discriminated on the basis of race because the percentage of Negro pupils in the school district was equally small.

The Court of Appeals for the Eighth Circuit reversed and found that Hazelwood had engaged in a pattern or practice of racial discrimination.

This finding was largely based on statistical evidence introduced by the Government showing a comparison of the percentage of Negroes on Hazelwood's teaching staff with the percentage of teachers in the area who were Negroes rather than with the percentage of Negro pupils in the Hazelwood District.

The relatively small percentage of Negro teachers employed by Hazelwood when coupled with the Government's other proof led the Court of Appeals to direct a final judgment against Hazelwood.

In the opinion filed today with the clerk, we vacate the judgment of the Court of Appeals and remand the case to the District Court for further proceedings.

The Court of Appeals correctly held that the District Court's comparison of the percentage of Negro teachers to the percentage of Negro pupils in Hazelwood was inappropriate one.

But the Court of Appeals was in error in undertaking to make the proper statistical comparisons itself instead of leaving them in the first instance for evaluation by the District Court.

Statistical comparisons are an important source of proof in Title VII cases but statistical data ordinarily require careful analysis and refinement and their value as evidence in an employment discrimination case depends upon all the surrounding circumstances.

The opinion for the Court outlines in greater detail some of the questions arising from the Court of Appeals statistical analysis.

Questions at the District Court would have to deal with on remand.

Only after those questions are resolved, will there be an adequate foundation for determining whether the Hazelwood School District engaged in a pattern or practice of racial discrimination in employment after the effective date of the federal law in 1972.

Mr. Justice Brennan and Mr. Justice White while joining the opinion of the Court have each filed concurring opinions and Mr. Justice Stevens has filed a dissenting opinion.