Albemarle Paper Co. v. Moody
Albemarle Paper Co. v. Moody | |
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Argued Apr 14, 1975 Decided June 25, 1975 | |
Full case name | Albemarle Paper Co. et al. v. Moody et al. |
Docket no. | 74-389 |
Citations | 422 U.S. 405 (more) 95 S. Ct.2362, L. Ed. 2d 280 |
Argument | Oral argument |
Reargument | Reargument |
Opinion announcement | Opinion announcement |
Case history | |
Prior | Moody v. Albemarle Paper Co., 474 F.2d 134 (4th Cir. 1973) |
Holding | |
Title VII plaintiffs do not need to prove bad faith to be entitled to backpay | |
Court membership | |
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Case opinions | |
Majority | Stewart, joined by Douglas, Brennan, Marshall, White |
Concurrence | Marshall |
Concurrence | Blackmun |
Concur/dissent | Burger |
Laws applied | |
Title VII of the Civil Rights Act of 1964 |
Albemarle Paper Co. v. Moody, 422 US 405 (1975), is a
Background
Before the enactment of
The new agreement changed the existing seniority system. The agreement opened lines of progression to black employees that were previously open only to white employees. However, the system left the plant's black employees behind its white ones on every line of progression. "The formerly 'Negro' lines of progression had been merely tacked on to the bottom of the formerly 'white' lines." In the 1950s, Albemarle began giving general ability tests to job applicants to sort them into the higher or lower-paying lines. Albemarle gave two tests, the Beta Examination and the
A class of former and then-present black employees sued Albemarle, as well as the union for violating Title VII. Initially, the plaintiffs sought only
The
The Supreme Court accepted cert to resolve the circuit split over the proper standard for awarding backpay, as well as what is required to show that pre-employment tests are sufficiently job-related.[1]
Supreme Court
The court rejected the idea that plaintiffs had to show their employers' violations of
However, Justice Stewart held that the plaintiffs may not be entitled to backpay if their demands for it are "tardy [and] inconsistent". The Supreme Court remanded to lower courts to decide if the plaintiffs were entitled to backpay in light of the court's opinion.
The Court also reaffirmed the holding of
To be sufficiently job-related, the tests must accurately measure the ability of applicants to perform the job in question. Albemarle's attempt at validation failed on multiple fronts. The Beta Examination only correlated to job performance on three of Albemarle's eight lines. Albemarle administered two versions of the Wonderlic that while "theoretically identical and interchangeable measures of verbal facility, significant correlations for one form but not for the other were obtained in four job groupings."[1] Neither form showed a correlation to two of the eight lines. Additionally, the standards by which supervisors evaluated employees were "extremely vague and fatally open to divergent interpretations."[1]
The court concluded that there was no way to know what criteria the supervisors were considering, or even whether different supervisors used the same criteria. There was therefore no way to know whether the criteria considered were sufficiently related to justify the employment practices with discriminatory impact.
The court vacated the Fourth Circuit's judgment and remanded to the district court for further proceedings.