Hazelwood School District et al. v. United States
433 U.S. 299 (1977)
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Rule of Law:
In a Title VII pattern or practice discrimination case, the proper statistical comparison is between the racial composition of an employer's workforce and the racial composition of the qualified population in the relevant labor market. An employer may rebut a prima facie case of discrimination by providing evidence that statistical disparities are the result of non-discriminatory hiring practices after the effective date of the Act, rather than pre-Act conduct.
Facts:
- Hazelwood School District is located in St. Louis County, Missouri.
- The district's hiring process was highly subjective, granting individual school principals virtually unlimited discretion to hire the 'most competent' person based on intangible factors.
- During recruitment efforts in the early 1960s, Hazelwood staff visited predominantly white colleges and did not seriously recruit at the two predominantly Black four-year colleges in Missouri.
- Hazelwood hired its first Black teacher in 1969.
- By the 1972-1973 school year, 1.4% of Hazelwood's teachers were Black.
- According to 1970 census data, 15.4% of teachers in the combined area of St. Louis County and St. Louis City were Black.
- If the St. Louis City School District (which had a policy to maintain a 50% Black teaching staff) was excluded, the percentage of Black teachers in St. Louis County alone was 5.7%.
Procedural Posture:
- The United States Attorney General sued the Hazelwood School District in the U.S. District Court for the Eastern District of Missouri, alleging a 'pattern or practice' of employment discrimination.
- The District Court (trial court) entered judgment for Hazelwood, finding the government had failed to establish a pattern or practice of discrimination.
- The United States, as appellant, appealed to the U.S. Court of Appeals for the Eighth Circuit.
- The Court of Appeals (intermediate appellate court) reversed the District Court's decision, finding the government had established a prima facie case, and it directed the trial court to enter judgment for the United States.
- The Hazelwood School District, as petitioner, was granted a writ of certiorari by the U.S. Supreme Court.
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Issue:
In a Title VII employment discrimination lawsuit, is a prima facie case of a 'pattern or practice' of discrimination established by a statistical comparison between the racial composition of an employer's teaching staff and the racial composition of teachers in a broad metropolitan area, without considering the employer's hiring statistics after Title VII became applicable to it?
Opinions:
Majority - Justice Stewart
No. A prima facie case of a 'pattern or practice' of discrimination is not conclusively established by such a comparison. While the Court of Appeals correctly identified that the proper comparison is between the employer's workforce and the qualified teacher population in the relevant labor market, it erred by substituting its own judgment for the trial court's. The appellate court failed to consider that Hazelwood's hiring statistics after March 24, 1972 (the date Title VII became applicable to public employers) might rebut the inference of discrimination. The case must be remanded for the District Court to determine the appropriate 'relevant labor market' and to evaluate Hazelwood's post-Act hiring data to see if the statistical disparity was a product of pre-Act hiring rather than unlawful post-Act discrimination.
Dissenting - Justice Stevens
Yes. The government's evidence was sufficient to establish a prima facie case that Hazelwood failed to rebut. The gross statistical disparities, combined with a history of discriminatory recruitment and the use of a standardless, subjective hiring process, clearly established a pattern of discrimination. Hazelwood offered virtually no evidence to challenge the government's case at trial. Remanding the case gives the defendant a second chance to litigate the issue, which is an inappropriate departure from standard procedure.
Concurring - Justice Brennan
I concur in the judgment to remand the case. The District Court applied an incorrect legal standard, so it must re-evaluate the factual record in a meaningful way. However, it is likely that even under the refined statistical analysis directed by the Court, the evidence will not aid Hazelwood in meeting its burden of proof. The remand is appropriate to allow the parties to address the figures with greater care, but the government's case appears strong and will likely prevail.
Analysis:
This case significantly clarified the use of statistical evidence in Title VII 'pattern or practice' lawsuits. It established that the correct comparison is to the 'qualified relevant labor market,' requiring courts to carefully define that market. Crucially, it distinguished between an employer's conduct before and after Title VII became applicable, allowing an employer to rebut a prima facie case based on workforce-wide statistics by showing its post-Act hiring was non-discriminatory. This holding protects employers from liability for historical imbalances they have since taken lawful steps to correct, while still permitting statistics to be powerful evidence of ongoing discrimination.
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