Wards Cove Packing Co. v. Atonio
Encyclopedia
Wards Cove Packing Co. v. Atonio, 490 U.S. 642
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...

 (1989), was a court case argued before the United States Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...

 on January 18, 1989. It concerned employment discrimination
Employment discrimination
Employment discrimination is discrimination in hiring, promotion, job assignment, termination, and compensation. It includes various types of harassment....

 and was decided on June 5, 1989.

Facts

A group of nonwhite cannery workers filed suit in District Court citing Title VII of the Civil Rights Act of 1964
Civil Rights Act of 1964
The Civil Rights Act of 1964 was a landmark piece of legislation in the United States that outlawed major forms of discrimination against African Americans and women, including racial segregation...

 complaining that Wards Cove Packing Co. owner of Alaskan salmon
Salmon
Salmon is the common name for several species of fish in the family Salmonidae. Several other fish in the same family are called trout; the difference is often said to be that salmon migrate and trout are resident, but this distinction does not strictly hold true...

 canneries, was using discriminatory
Discrimination
Discrimination is the prejudicial treatment of an individual based on their membership in a certain group or category. It involves the actual behaviors towards groups such as excluding or restricting members of one group from opportunities that are available to another group. The term began to be...

 hiring practices that resulted in a large number of the skilled noncannery jobs to be filled by white workers and a large number of the unskilled cannery jobs to be filled by nonwhites. In this case the nonwhite workers were predominantly native Alaskans and Filipinos. The District Court case was found in favor of the defendants, Wards Cove Packing Co.

The Plaintiffs appealed to the United States Court of Appeals for the Ninth Circuit which reversed the District Court decision stating the Petitioners, the Plaintiffs in the District Court, had made a prima facie case of disparate impact. The decision was based on statistics provided by the Petitioners that showed a high percentage of nonwhite workers in the cannery jobs and a low percentage of the noncannery jobs filled by nonwhite workers.

Judgment

Wards Cove Packing Co. then appealed the Court of Appeals' ruling to the United States Supreme Court. The Supreme Court determined that the Court of Appeals had erred by using inappropriate statistics and comparison. The majority determined that the proper comparison was to compare the percentage of nonwhite workers in noncannery jobs with the percentage of the available labor pool that were nonwhite and who had the appropriate skills to perform the noncannery jobs.

The Supreme Court remanded the case back to the Court of Appeals with instructions to use the more appropriate comparison. Further if on remand the Respondents did establish a prima facie disparate-impact case the Petitioners would then need to "produce evidence of a legitimate business justification" for the hiring practices that created the disparity.

Significance

Soon after the decision Congress then Amended Title VII with the Civil Rights Act of 1991
Civil Rights Act of 1991
The Civil Rights Act of 1991 is a United States statute that was passed in response to a series of United States Supreme Court decisions which limited the rights of employees who had sued their employers for discrimination...

 to counter the Supreme Court's holding in Ward's Cove, thereby nullifying the case's precedent. The bill, in part, reads:


See also


External links

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