Dawavendewa v. Salt River Project Agricultural Improvement & Power District
United States Court of Appeals for the Ninth Circuit
154 F.3d 1117 (1998)

- Written by Sean Carroll, JD
Facts
The Salt River Project Agricultural Improvement and Power District (SRP) (defendant) leased land from the Navajo Nation. Under the lease, the SRP was required to give hiring preference to local Navajos. Harold Dawavendewa (plaintiff), a Hopi, applied for a job but was denied an interview. Dawavendewa sued SRP in federal court for violations of Title VII of the Civil Rights Act of 1964 (Title VII). SRP moved to dismiss on the ground that differential employment treatment based on membership in a specific Native American tribe, as opposed to based on status as a Native American generally, was not actionable as national-origin discrimination under Title VII. The district court granted SRP’s motion to dismiss. Dawavendewa appealed.
Rule of Law
Issue
Holding and Reasoning (Reinhardt, J.)
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