Washington v. Davis Case Brief

Facts of the case

After the applications of two blacks were rejected by the District of Columbia Police Department, the two men filed suit against Mayor Walter E. Washington. The men alleged that the Department’s recruiting procedures, including a written personnel test, discriminated against racial minorities. They claimed that the test was unrelated to job performance and excluded a disproportionate number of black applicants.

Why is the case important?

A higher percentage of black applicants than white applicants failed a qualifying test administered by the District of Columbia Police Department. Some of the unsuccessful black applicants claimed these effects constituted unconstitutional discrimination against them.

Question

Was proof of the disproportionate effects of the qualifying exam sufficient to ground a finding that the exam unconstitutionally discriminated against the respondents?

ANSWER

No. The Court of Appeals, reversing the District Court, is reversed.
Justice Byron White (J. White) said our cases have not embraced the proposition that a law can be a violation of equal protection on the basis of its effect, without regard for governmental intent. Disproportionate impact is not irrelevant, but it alone does not trigger the rule that racial classifications are subject to the strict scrutiny standard of review. The police force’s efforts to recruit black police officers are evidence that the police department did not intentionally discriminate on the basis of race.
The exam is rationally related to the legitimate government purpose of ensuring that police officers have acquired a particular level of verbal skill.
Concurrence. Justice John Paul Stevens (J. Steven) said that frequently the most probative evidence of intent will be a showing of what actually happened. A Constitutional issue does not arise, however, every time some disproportionate impact is shown.

CONCLUSION

On certiorari, the Supreme Court of the United States reversed the judgment. The Court determined that the appellate court erroneously applied legal standards applicable to Title VII cases. The Court held that a statute, which was otherwise neutral on its face, had to be applied so as to invidiously discriminate on the basis of race. The police department’s efforts to recruit black officers, the changing racial composition of the recruit classes, and the relationship of the test to the training program negated any inference that the police department discriminated on the basis of race or that a police officer qualified on the color of his skin rather than ability. Thus, it was error for to direct summary judgment for the police recruits.

  • Advocates: Mark L. Evans Argued the cause for the US Civil Service Commission as respondents under Rule 21 (4) Richard B. Sobol Argued the cause for the respondents Harley et al David P. Sutton Argued the cause for the petitioners
  • Petitioner: Washington
  • Respondent: Davis
  • DECIDED BY:Burger Court
  • Location: Metropolitan Police Department
Citation: 426 US 229 (1976)
Argued: Mar 1, 1976
Decided: Jun 7, 1976
Washington v. Davis Case Brief