Saint Francis College v. Al-Khazraji

Supreme Court of the United States
481 U.S. 604, 95 L. Ed. 2d 582, 1987 U.S. LEXIS 2054 (1987)

ELI5:

Rule of Law:

A claim of racial discrimination under 42 U.S.C. § 1981 is not limited to discrimination based on modern racial classifications but extends to intentional discrimination based on an individual's ancestry or ethnic characteristics, as understood at the time the statute was enacted.

Facts:

Respondent, a United States citizen born in Iraq, was an associate professor at St. Francis College.
In January 1978, the respondent applied for tenure.
On February 23, 1978, the college's Board of Trustees denied his request for tenure.
The respondent accepted a final, one-year, nonrenewable contract.
The college denied his request for administrative reconsideration of the tenure decision on February 6, 1979.
The respondent alleged that the tenure denial was a result of discrimination based on his Arabian ancestry.

Procedural Posture:

The respondent filed a complaint in U.S. District Court against St. Francis College, alleging violations of § 1981 and other statutes.
The District Court initially allowed the § 1981 claim but later, on a motion for summary judgment, dismissed it, ruling that the statute did not protect against discrimination based on Arabian ancestry.
The respondent (as appellant) appealed to the U.S. Court of Appeals for the Third Circuit.
The Court of Appeals reversed the District Court's decision, holding that § 1981 does protect individuals of Arabian ancestry from racial discrimination.
St. Francis College (as petitioner) successfully petitioned the U.S. Supreme Court for a writ of certiorari.

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Issue:

Does 42 U.S.C. § 1981 prohibit racial discrimination against an individual of Arabian ancestry, who may be considered Caucasian under modern racial classifications?

Opinions:

Majority - Justice White

Yes. 42 U.S.C. § 1981 prohibits racial discrimination against individuals of Arabian ancestry. The Court reasoned that the understanding of 'race' when § 1981 was passed in the 19th century was much broader than modern scientific classifications. Legislative history and contemporary sources show that Congress considered various ethnic groups, such as Germans, Scandinavians, Jews, and Arabs, to be distinct races. Therefore, Congress intended the statute to protect identifiable classes of persons from intentional discrimination based on their ancestry or ethnic characteristics. To succeed, the respondent must prove he was discriminated against for being an Arab, not solely based on his nation of origin or religion.

Concurring - Justice Brennan

Yes. Justice Brennan agreed with the Court's conclusion but wrote separately to highlight that the line between discrimination based on 'ancestry or ethnic characteristics' and 'place or nation of origin' is not always clear. He noted that in many instances, ancestry and national origin are factually identical. He interpreted the majority's opinion to mean that discrimination based solely on one's birthplace is insufficient for a § 1981 claim, but acknowledged the significant overlap between the concepts, particularly as treated in other areas of civil rights law like Title VII.

Analysis:

This decision significantly broadened the applicability of § 1981 by interpreting 'racial' discrimination through a historical lens rather than a modern, scientific one. It established that groups considered 'Caucasian' today, such as Arabs and Jews, could still be victims of racial discrimination under the statute if they were targeted for their distinct ancestry or ethnic characteristics. This expanded protections for various ethnic minorities and clarified that the statute's scope is determined by the social and historical context in which it was written, preventing defendants from using narrow, modern definitions of race to escape liability.

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