Teamsters v. United States
431 U.S. 324 (1977)
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Rule of Law:
A bona fide seniority system that is neutral in its application and was not created with discriminatory intent does not violate Title VII of the Civil Rights Act of 1964, even if it perpetuates the effects of racial discrimination that occurred before the Act's passage. For post-Act discrimination, after the government proves a pattern or practice of discrimination, the evidentiary burden shifts to the employer to show that individual employment decisions were made for legitimate, nondiscriminatory reasons.
Facts:
- T.I.M.E.-D.C., Inc., a nationwide motor freight carrier, had a historical practice of hiring Black and Spanish-surnamed individuals for lower-paying jobs like servicemen or local city drivers.
- The company almost exclusively hired white men for the more desirable and higher-paying 'line driver' (long-haul) positions.
- The collective bargaining agreement with the International Brotherhood of Teamsters established a seniority system based on time within a specific bargaining unit (e.g., 'line driver' or 'city driver').
- Under this system, any employee transferring to a line driver job, including city drivers, forfeited all competitive seniority earned in their previous bargaining unit and started at the bottom of the line drivers' seniority list.
- This seniority forfeiture rule, while facially neutral, disproportionately disadvantaged minority employees who had been discriminatorily excluded from line driver jobs when they were first hired.
- The company continued its pattern of discriminatory hiring for line driver positions for several years after the effective date of Title VII in 1965.
Procedural Posture:
- The United States sued T.I.M.E.-D.C., Inc. and the International Brotherhood of Teamsters in federal district court, alleging a pattern or practice of employment discrimination.
- The U.S. District Court for the Northern District of Texas found that the company had engaged in discrimination and that the union contract's seniority system violated Title VII.
- The District Court awarded injunctive relief and limited retroactive seniority to certain classes of victims.
- The company and the union, as appellants, appealed to the U.S. Court of Appeals for the Fifth Circuit.
- The Court of Appeals affirmed the finding of a Title VII violation but expanded the remedy, holding that all victims were entitled to full retroactive seniority based on a 'qualification date' formula.
- The Supreme Court granted certiorari at the request of T.I.M.E.-D.C. and the Teamsters union.
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Issue:
Does an otherwise neutral, bona fide seniority system that perpetuates the effects of an employer's pre-Act racial discrimination violate Title VII of the Civil Rights Act of 1964?
Opinions:
Majority - Justice Stewart
No. An otherwise neutral, legitimate seniority system does not become unlawful under Title VII simply because it may perpetuate pre-Act discrimination. The court affirmed the finding that T.I.M.E.-D.C. engaged in a pattern of post-Act discrimination, but held that the seniority system itself was protected by § 703(h) of Title VII. The legislative history of the Civil Rights Act of 1964 shows a clear congressional intent to protect existing, 'bona fide' seniority rights. A system is 'bona fide' if it is facially neutral, applies to all races, was not created with a discriminatory purpose, and is rational in its structure. The Teamsters' system met these criteria. Therefore, its routine application is not an unlawful employment practice, even if it carries forward the effects of discrimination that predated the Act. However, victims of discrimination that occurred after the Act's effective date are entitled to 'make whole' relief, including an award of retroactive seniority to the date they were discriminatorily denied the position.
Concurring-in-part-and-dissenting-in-part - Justice Marshall
Yes. The seniority system violates Title VII because it 'freezes' the status quo of prior discriminatory employment practices, which runs contrary to the core purpose of the Act. Section 703(h) is a narrow exemption and should not protect a system where current disadvantages are a direct 'result of an intention to discriminate' in the past. The majority's reliance on legislative history is misplaced, as Congress did not contemplate the specific problem of incumbent minorities being locked into inferior jobs. The court's decision effectively writes off an entire generation of minority employees. Furthermore, the 1972 amendments to Title VII show that Congress approved of lower court rulings that had invalidated such seniority systems, an indication of legislative intent that the majority improperly ignores.
Analysis:
This landmark decision significantly limited the scope of the disparate impact theory from Griggs v. Duke Power Co. by creating a broad immunity for bona fide seniority systems under § 703(h). It established that the perpetuation of pre-Act discrimination is not, by itself, a continuing violation of Title VII, thereby insulating many established labor agreements from challenge. The case solidified a burden-shifting framework for pattern-or-practice litigation, easing the path to relief for individual victims once systemic discrimination is proven. However, by protecting the vested seniority rights of non-minority employees, the ruling delayed the full integration of the workforce and the achievement of economic equality for many victims of past discrimination.
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