International Brotherhood of Teamsters v. United States

Summary

The Supreme Court considered whether an employer and union violated Title VII through discriminatory employment practices and a seniority system that perpetuated the effects of prior racial and ethnic discrimination. The Court upheld findings that the employer engaged in a systemwide pattern or practice of discrimination and addressed the application of Title VII's seniority-system provision, including remedies for affected employees.

Holdings

1. The Government proved that the employer engaged in a systemwide pattern or practice of purposeful racial and ethnic discrimination in hiring, assignment, transfer, and promotion.
2. Statistics are competent and potentially powerful evidence of employment discrimination, although they are not conclusive and must be evaluated in light of all surrounding facts and circumstances.
3. An otherwise neutral and bona fide seniority system does not violate Title VII merely because it perpetuates the effects of pre-Act discrimination.
4. At the liability stage of a pattern-or-practice action, the Government need prove only that unlawful discrimination was the employer's regular procedure or policy; it need not prove that every individual for whom relief may later be sought was a victim.
5. After the Government proves a pattern or practice of discrimination, a post-Act minority applicant who unsuccessfully applied for a line-driver position is presumptively entitled to relief, subject to the employer's showing that the particular refusal was based on a lawful reason.
6. An incumbent employee's failure to formally apply for a job is not an inexorable bar to retroactive seniority or other Title VII relief.
7. A nonapplicant seeking relief must prove that he or she would have applied for the job absent the discriminatory practices and possessed the relevant qualifications; proof of a general discriminatory policy alone does not establish that every nonapplicant was a victim.
8. The District Court must exercise equitable discretion after individualized hearings to determine the scope and allocation of relief, balancing the rights of actual discriminatees against the legitimate expectations of innocent employees.

Questions Presented

1. Whether the employer engaged in a systemwide pattern or practice of intentional employment discrimination in violation of Title VII.
2. Whether statistical and anecdotal evidence was sufficient to establish a prima facie pattern or practice of employment discrimination.
3. Whether an otherwise bona fide, neutral seniority system violates Title VII merely because it perpetuates the effects of pre-Act discrimination.
4. Whether proof of a pattern or practice shifts to the employer the burden of disproving individual entitlement to relief during remedial proceedings.
5. Whether an incumbent employee's failure to make a formal application categorically bars an award of retroactive seniority or other Title VII relief.
6. How the District Court should determine the scope and allocation of equitable relief among actual discriminatees and innocent employees with competing seniority or recall expectations.

Disposition

vacated