East Texas Motor Freight System, Inc. v. Rodriguez
United States Supreme Court
431 U.S. 395 (1977)

- Written by Mary Phelan D'Isa, JD
Facts
Jesse Rodriguez, Sadrach Perez, and Modesto Herrera (class representatives) (plaintiffs) filed a Title VII employment-discrimination case in a federal district court in Texas against their employer, East Texas Motor Freight System, Inc., and trucking-industry unions (East Texas) (defendants). East Texas had a policy and a collective-bargaining agreement with unions that included a no-transfer policy prohibiting city drivers from transferring to line-driver jobs and limiting line drivers’ seniority to time spent in a particular bargaining unit, excluding time drivers may have spent in other jobs with the company. The class representatives challenged these practices in their class-action complaint, but they never moved for nor offered any evidence to support class certification while the case was pending in the district court. Citing that failure and the fact that most union members voted against a proposed merger of driver seniority lines and free transfer between jobs, the district court dismissed the class allegations. The district court also dismissed the class representatives’ individual claims because none of them qualified for a line-driver position. The Circuit Court of Appeals for the Fifth Circuit reversed. Noting that the requirements for class-action certification in Federal Rule of Civil Procedure 23(a) must be read liberally in Title VII and 42 U.S.C. § 1981 cases, the court certified what it considered to be an appropriate class and ruled that East Texas’s no-transfer rule violated Title VII and § 1981. The United States Supreme Court granted certiorari.
Rule of Law
Issue
Holding and Reasoning (Stewart, J.)
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