Hazelwood School District v. United States

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1977 United States Supreme Court case

Hazelwood School Dist. v. United States

Supreme Court of the United States

Argued April 27, 1977
Decided June 27, 1977
Full case name| Hazelwood School District v. United States
Citations| 433 U.S. 299 (more)

97 S. Ct. 2736; 53 L. Ed. 2d 768; 1977 U.S. LEXIS 142

Case history
Prior| Judgment for defendants, 392 F. Supp. 1276 (E.D. Mo. 1975); reversed, 534 F.2d 805 (8th Cir. 1976); certiorari granted, 429 U.S. 1037 (year).
Holding
In addition to considering the correct relevant labor market in a Title VII disparate-impact case, consider whether the impact that could have been caused by actions taken before Title VII was applied to the employer.
Court membership

Chief Justice
Warren E. Burger
Associate Justices
William J. Brennan Jr. · Potter Stewart
Byron White · Thurgood Marshall
Harry Blackmun · Lewis F. Powell Jr.
William Rehnquist · John P. Stevens
Case opinions
Majority| Stewart, joined by Burger, Brennan, White, Marshall, Blackmun, Powell, Rehnquist
Concurrence| Brennan
Concurrence| White
Dissent| Stevens
Laws applied
Title VII of the Civil Rights Act of 1964

English Wikisource has original text related to this article:

Hazelwood School Dist. v. United States

Hazelwood School District v. United States, 433 U.S. 299 (1977), was a court case argued before the United States Supreme Court on April 27, 1977. It concerned employment discrimination and was decided on June 27, 1977.[1]

## Case

[edit]

In 1969, the Hazelwood School District in Missouri hired its first black teacher, and continued hiring black teachers ever since. In 1972, the Civil Rights Act of 1964 was amended to apply to public employers, including school districts, making the hiring of black teachers almost a necessity in order to avoid liability. However, due to statistical disparities in the hiring practices of this particular school district, as well as 55 individual cases of alleged discrimination, the United States brought suit in the United States District Court for the Eastern District of Missouri to enjoin the school district from discriminating based on race. The District Court found in favor of the school district, saying that the ratio of black teachers to white was roughly equivalent to the ratio of black students to white.[2]

The United States appealed to the United States Court of Appeals for the Eighth Circuit, which reversed the District Court's decision.[3] This judgment was based on their decision to disregard the comparison to the student population, and instead compare the Hazelwood hiring statistics to the statistics of the surrounding area, including the St. Louis, MO school districts, saying that those numbers would more accurately reflect the "relevant labor market[.]"[1]: 304  Hazelwood appealed to the Supreme Court to review the Court of Appeals decision, arguing that the relevant labor market statistics should not include the St. Louis numbers, because that city had imposed very strict hiring guidelines to help overcome past racial discrimination.[1]: 311

## Judgment

[edit]

The Supreme Court decided that, in this case, the proximity of the questionable hiring statistics to the application of Title VII to public employers was very relevant. The primary reason for the ultimate decision of the Court was that "pre-Act" hiring practices, that were perfectly legal under Title VII until the 1972 amendment, might have caused the statistical disparities in question.[1]: 310  Based on that fact and the warning in the recent Teamsters decision that, when considering statistics as evidence of discrimination, all of the facts must be carefully considered,[1]: 312  the Court vacated the decision of the Court of Appeals and remanded to the District Court for further proceedings, instructing them to consider whether the pre-Act practices might have played a predominant role in the statistics.[1]: 313

## Significance

[edit]

This case solidified the decision in Teamsters v. United States, where the Court decided that statistics could play a leading role in showing a prima facie case of discrimination under Title VII, but that they must be used with great care. The Teamsters decision was very important in the evolution of disparate impact jurisprudence, and made it much easier for the victims of discrimination to bring cases against their employers. Hazelwood somewhat weakened that decision, however, by noting that statistics which were caused by actions taken legally, before the application of anti-discrimination laws, could not be used in such a way, and that an employer must be given a chance to prove that that might be the case, before a prima facie case can be said to have been established.

## See also

[edit]

* List of United States Supreme Court cases, volume 433
* Hazelwood v. Kuhlmeier

## Notes

[edit]

1. ^ a b c d e f Hazelwood School District v. United States, 433 U.S. 299 (1977).
2. ^ United States v. Hazelwood School District, 392 F. Supp. 1276 (E.D. Mo. 1975).
3. ^ United States v. Hazelwood School District, 534 F.2d 805 (8th Cir. 1976).

## External links

[edit]

* Works related to Hazelwood School Dist. v. United States at Wikisource
* Text of Hazelwood School District v. United States, 433 U.S. 299 (1977) is available from: CourtListener Findlaw Google Scholar Justia Library of Congress Oyez (oral argument audio)

* v
* t
* e

Affirmative action in the United States

Supreme Court and
lower court decisions|

| Education|

* DeFunis v. Odegaard (1974)
* Regents of the University of California v. Bakke (1978)
* United States v. Fordice (1992)
* Hopwood v. Texas (5th Cir. 1996)
* Texas v. Lesage (1999)
* Gratz v. Bollinger (2003)
* Grutter v. Bollinger (2003)
* Doe v. Kamehameha Schools/Bernice Pauahi Bishop Estate (9th Cir. 2006)
* Parents Involved in Community Schools v. Seattle School District No. 1 (2007)
* Fisher v. University of Texas I (2013)
* Schuette v. Coalition to Defend Affirmative Action (2014)
* Fisher v. University of Texas II (2016)
* Coalition for TJ v. Fairfax County School Board (4th Cir. 2023)
* Students for Fair Admissions v. Harvard (2023)

|

Employment|

* Griggs v. Duke Power Co. (1971)
* Morton v. Mancari (1974)
* Schlesinger v. Ballard (1975)
* Hazelwood School District v. United States (1977)
* United Steelworkers v. Weber (1979)
* Firefighters v. Stotts (1984)
* Wygant v. Jackson Board of Education (1986)
* Sheet Metal Workers v. EEOC (1986)
* Firefighters v. City of Cleveland (1986)
* United States v. Paradise (1987)
* Johnson v. Transportation Agency (1987)
* Wards Cove Packing Co. v. Atonio (1989)
* Piscataway School Board v. Taxman (3d Cir. 1996)
* Ricci v. DeStefano (2009)
* Charlton-Perkins v. University of Cincinnati (6th Cir. 2022)

Grants,
Contracting,
and Set-Asides|

* Kahn v. Shevin (1974)
* Califano v. Webster (1977)
* Fullilove v. Klutznick (1980)
* City of Richmond v. J.A. Croson Co. (1989)
* Metro Broadcasting, Inc. v. FCC (1990)
* Lamprecht v. FCC (D.C. Cir. 1992)
* Northeastern Fla. Chapter, Associated Gen. Contractors of America v. City of Jacksonville (1993)
* Adarand Constructors, Inc. v. Peña (1995)
* Adarand Constructors, Inc. v. Slater (2000)
* Adarand Constructors, Inc. v. Mineta (2001)
* Vitolo v. Guzman (6th Cir. 2021)

Federal legislation
and edicts|

* Section 1981 of the Civil Rights Act of 1866
* Equal Protection Clause of the Fourteenth Amendment (1868)
* Executive Order 10925 (1961)
* Title VI of the Civil Rights Act of 1964
* Title VII of the Civil Rights Act of 1964
* Executive Order 11246 (1965)

State initiatives|

* Proposition 209 (CA, 1996)
* Initiative 200 (WA, 1998)
* Proposal 2 (MI, 2006)
* Amendment 46 (CO, 2008, failed)
* Initiative 424 (NE, 2008)
* Proposition 107 (AZ, 2010)
* State Question 759 (OK, 2012)
* Referendum 88 (WA, 2019, failed)
* Proposition 16 (CA, 2020, failed)

People|

* Peter Arcidiacono
* Edward Blum
* Carl Cohen
* Ward Connerly
* Arthur Fletcher
* Richard Kahlenberg
* Richard Sander
* Stuart Taylor Jr.
* Abigail Thermstrom
* Stephan Thermstrom
* Ron Unz

* v
* t
* e

Education in St. Louis County, Missouri

This includes institutions outside of the city limits of St. Louis which have "St. Louis, MO" postal addresses.
Note multiple places with "St. Louis, MO" postal addresses are not in the St. Louis city limits.

K-12

School districts|

* Affton
* Bayless
* Brentwood
* Clayton
* Ferguson-Florissant
* Hancock Place
* Hazelwood
* Jennings
* Kirkwood
* Ladue
* Lindbergh
* Maplewood Richmond Heights
* Mehlville
* Meramec Valley R-III
* Normandy Collab
* Parkway
* Pattonville
* Rittenour
* Riverview Gardens
* Rockwood
* University City
* Valley Park
* Webster Groves

| Closed|

* Wellston

|

Special district|

* Special School District of St. Louis County

Public
high schools|

* Affton
* Clayton
* Eureka
* Fern Ridge
* Hazelwood Central
* Hazelwood East
* Hazelwood West
* Kirkwood
* McCluer
* McCluer North
* Melhville
* Normandy
* Parkway Central
* Parkway North
* Parkway South
* Parkway West
* Pattonville
* STEAM Academy at McCluer South-Berkeley
* University City
* Valley Park

| Closed|

* Berkeley
* Douglass
* Kinloch

|

Private
high schools|

* Barat Acad
* Chaminade College Prep
* CBC HS
* Cor Jesu Acad
* De Smet Jesuit HS
* Incarnate Word Acad
* John Burroughs
* Logos HS
* Lutheran North
* Lutheran South
* Nerinx Hall HS
* Notre Dame HS
* Principia
* St. John Vianney HS
* St. Joseph's Acad
* Saint Louis Priory
* Ursuline Acad
* Villa Duchesne
* Visitation Acad
* Westminster Christian Acad
* Whitfield School

| Closed|

* Trinity Catholic

|

Tertiary institutions

Four-year|

* Fontbonne University
* Maryville University
* Missouri Baptist University
* Washington University in St. Louis
* Webster University

Community
college|

* St. Louis Community College

Seminaries|

* Concordia Seminary
* Covenant Theological Seminary

Supplementary education

Weekend
schools|

* St. Louis Japanese School

This list may be incomplete
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