Dothard v. Rawlinson
United States Supreme Court
433 U.S. 321 (1977)
Rawlinson (plaintiff), a 22-year-old woman with college training in correctional psychology, applied for a position as a correctional counselor trainee in Alabama. An Alabama statute required that state correctional facility employees maintain a minimum weight of 120 pounds and have a minimum height of 5 foot 2 inches. Correctional counselors’ primary duty was to maintain security and control over inmates through constant supervision and observation. In addition to the height and weight requirements, correctional counselors were required to have a valid Alabama driver’s license and a high school or equivalent degree, have no physical defects, and fall between the ages of 20.5 and 45 years at the time of employment. Outside these criteria, correctional counselors were selected by merit, based on education and prior experience. They were not subject to any written exam. Rawlinson was denied employment, because she did not meet the minimum weight requirement. She sued the Alabama Board of Corrections (the State) (defendant) under Title VII of the Civil Rights Act of 1964 (Title VII), 42 U.S.C. § 2000e et seq., alleging that the statutory height and weight requirements, though facially neutral, functionally operated to disproportionately exclude women from employment in the State’s correctional facilities. The district court found that when combined, Alabama’s statutory height and weight requirements would exclude 41.13 percent of the United States’ female population but less than 1 percent of its male population. The district court concluded that Rawlinson made a prima facie showing of unlawful sex discrimination, which the State did not sufficiently rebut. The State appealed directly to the United States Supreme Court, arguing that the district court erroneously permitted Rawlinson to rely on generalized national statistics to make a prima facie case rather than requiring more specific statistical evidence about actual correctional counselor applicants in Alabama. The State further argued it had successfully rebutted Rawlinson’s prima facie case by showing that the height and weight requirements were job related.
Rule of Law
Holding and Reasoning (Stewart, J.)
Concurrence (Rehnquist, J.)
Dissent (White, J.)
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