Lexplug logoLexplug

Cooper v. Federal Reserve Bank of Richmond

Supreme Court of United States
467 U.S. 867 (1984)
ELI5:

Rule of Law:

A judgment in a class action lawsuit finding that an employer did not engage in a general pattern or practice of racial discrimination does not preclude individual class members from subsequently bringing their own civil actions alleging specific, individual acts of discrimination.


Facts:

  • Phyllis Baxter and five other black employees (the Baxter petitioners) worked for the Federal Reserve Bank of Richmond (the Bank) in its Charlotte branch.
  • A class action lawsuit was initiated against the Bank, alleging a pattern or practice of racial discrimination in promotions and other employment conditions on behalf of a class that included the Baxter petitioners.
  • The Baxter petitioners received notice of the class action but chose not to exclude themselves, thereby remaining members of the class.
  • The Baxter petitioners all worked in pay grades higher than grade 5.
  • During the class action trial, the Baxter petitioners testified about their individual experiences with alleged discrimination.
  • Following an initial court ruling in the class action, the Baxter petitioners filed a separate, individual lawsuit against the Bank, alleging that each of them had been denied promotions due to their race.

Procedural Posture:

  • The EEOC filed a civil action against the Federal Reserve Bank of Richmond (the Bank) in federal district court, alleging racial discrimination.
  • Four employees (the Cooper plaintiffs) intervened, adding a class action claim on behalf of black employees at the Bank's Charlotte branch.
  • The District Court certified the class and, after a trial, found a pattern of discrimination only in pay grades 4 and 5.
  • The Baxter petitioners, class members in grades higher than 5, moved to intervene to pursue individual claims, but the District Court denied their motion.
  • The Baxter petitioners then filed a separate action in the same District Court against the Bank, alleging individual claims of race discrimination.
  • The Bank moved to dismiss the Baxter lawsuit on grounds of res judicata, which the District Court denied.
  • The Bank appealed the denial to the U.S. Court of Appeals for the Fourth Circuit, which was consolidated with the appeal from the main Cooper litigation.
  • The Court of Appeals reversed the District Court's finding of a pattern of discrimination in the Cooper case and held that this judgment precluded the Baxter petitioners' individual claims, ordering their separate action to be dismissed.
  • The Baxter petitioners successfully petitioned the U.S. Supreme Court for a writ of certiorari.

Locked

Premium Content

Subscribe to Lexplug to view the complete brief

You're viewing a preview with Rule of Law, Facts, and Procedural Posture

Issue:

Does a judgment in a class action, which finds that an employer did not engage in a general pattern or practice of racial discrimination, preclude individual class members from subsequently filing their own lawsuits alleging specific instances of racial discrimination?


Opinions:

Majority - Justice Stevens

No. A judgment in a class action that finds no general pattern or practice of discrimination does not preclude individual class members from later suing for individual acts of discrimination. The court reasoned that there is a crucial distinction between an individual's claim of discrimination and a class action's claim of a general pattern or practice. Proving a pattern or practice requires showing that discrimination was the employer's 'standard operating procedure,' which is a different and higher burden than proving an individual was the victim of a specific discriminatory act under the McDonnell Douglas framework. The rejection of the class-wide claim does not decide the merits of any individual's claim because 'a racially balanced work force cannot immunize an employer from liability for specific acts of discrimination.' The prior judgment only bars the class members from bringing another class action on the same pattern-or-practice theory and from relitigating the specific issue of whether such a pattern existed; it is not dispositive of their individual claims.



Analysis:

This decision clarifies the scope of res judicata (claim preclusion) in Title VII class actions, ensuring that the procedural device does not extinguish valid individual rights. It establishes that a finding on a class-wide 'pattern or practice' claim is not legally equivalent to an adjudication of numerous individual discrimination claims. This preserves the ability of individual class members to seek redress for specific discriminatory acts even when their class action fails to prove systemic discrimination, preventing employers from using a favorable class action judgment as a complete shield against future liability to class members.

G

Gunnerbot

AI-powered case assistant

Loaded: Cooper v. Federal Reserve Bank of Richmond (1984)

Try: "What was the holding?" or "Explain the dissent"