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Espinoza v. Farah Manufacturing Co.

414 U.S. 86 (1973)

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Espinoza v. Farah Manufacturing Co.

United States Supreme Court

414 U.S. 86 (1973)

Facts

Cecilia Espinoza (plaintiff) was a Mexican citizen who lawfully resided in San Antonio, Texas, with her husband, Rudolfo Espinoza (plaintiff), a United States citizen. In 1969, Farah Manufacturing Co. (Farah) (defendant) rejected Cecilia Espinoza’s application to work as a seamstress, citing its longstanding company policy against hiring non-United States citizens. At Farah’s San Antonio division, 97 percent of seamstresses were of Mexican descent. The Espinozas exhausted their administrative remedies with the Equal Employment Opportunity Commission (EEOC), and then they sued Farah in federal court, alleging that Farah violated Title VII of the Civil Rights Act of 1964 by discriminating against Cecilia Espinoza based on her national origin. The district court granted the Espinozas’ summary-judgment motion, holding that refusal to hire someone based on her lack of citizenship is a form of national-origin discrimination. The appellate court reversed, holding that Title VII’s prohibition against national-origin discrimination does not include citizenship discrimination. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Marshall, J.)

Dissent (Douglas, J.)

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