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California Brewers Association v. Bryant

444 U.S. 598 (1980)

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California Brewers Association v. Bryant

United States Supreme Court

444 U.S. 598 (1980)

Facts

Beginning in May 1968, Bryant (plaintiff), who was Black, worked intermittently as a temporary employee of the Falstaff Brewing Corporation (defendant). A collective-bargaining agreement (the CBA) governed employment relations between seven breweries and certain unions on behalf of brewing-industry employees including Bryant. Under the CBA, a permanent employee was anyone who had worked at least 45 weeks in the preceding calendar year. A temporary employee was anyone who had worked at least 60 days in the preceding year. Permanent employees had substantially more favorable rights in terms of hiring and layoffs. Bryant sued seven brewing companies and several unions (the brewing entities) (defendants) under Title VII of the Civil Rights Act of 1964 (Title VII). The complaint alleged that historical discrimination against Black people was being perpetuated by the CBA because attaining permanent status under the 45-week rule was highly improbable. The district court dismissed the complaint for failure to state a claim. The court of appeals reversed, holding that the 45-week scheme was not a seniority system that would exempt the brewing entities from Title VII liability. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Stewart, J.)

Dissent (Marshall, J.)

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