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Garcia v. Spun Steak Co.

998 F.2d 1480 (1993)

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Garcia v. Spun Steak Co.

United States Court of Appeals for the Ninth Circuit

998 F.2d 1480 (1993)

Facts

Spun Steak Company (defendant) was an employer that adopted a policy requiring employees to speak only English while performing their duties. The majority of Spun Steak’s employees spoke English and Spanish and were Hispanic. Spun Steak adopted the English-only policy in response to complaints that two of the bilingual workers, Priscilla Garcia (plaintiff) and another worker, made harassing and racist comments in Spanish about an African American employee and a Chinese American employee who did not understand Spanish. Spun Steak believed the policy would preserve harmony between the races and offer other benefits relative to employee safety and the quality of its products. Garcia filed a complaint with the Equal Employment Opportunity Commission (EEOC) alleging discrimination. The EEOC’s investigation concluded that Spun Steak’s English-only policy likely violated Title VII of the Civil Rights Act of 1964. Based on this ruling, Garcia filed suit in federal district court alleging Spun Steak had violated Title VII. The district court granted summary judgment for Garcia, holding that Garcia established a prima facie case and Spun Steak’s justification was insufficient. The case came before the United States Court of Appeals for the Ninth Circuit.

Rule of Law

Issue

Holding and Reasoning (O’Scannlain, J.)

Concurrence/Dissent (Boochever, J.)

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