Hazelwood School District v. United States

The United States Attorney General (United States) (plaintiff) sued the Hazelwood School District (District) (defendant), alleging a pattern of employment discrimination by the District in violation of Title VII of the Civil Rights Act of 1964. The District, which was located in St. Louis County, Missouri, was formed between 1949 and 1951 by consolidating 13 smaller districts. The student population was predominantly white; by the 1972-73 school year, only 2 percent of students were black. The District’s teacher-hiring policies were not well defined. During the late 1960s and early 1970s, the District’s personnel office began a practice of randomly selecting three to 10 applicants to interview for vacant positions. The personnel office did not consider any criteria other than an applicant’s eligibility for state certification, and applicants who most recently submitted applications were more likely to be chosen. Principals had wide discretion in hiring decisions; they were subject to very little official guidance, and the superintendent and board of education always affirmed their choices. Between 1972 and 1974, less than 2 percent of the District’s teaching staff was black. By comparison, the average percentage of black teachers in nearby school districts was 15.4 percent. The latter included the City of St. Louis, which had a policy of maintaining a 50 percent black teaching staff. The district court held that the United States had not established a pattern or practice of discrimination. The court found nothing suspect in the District's teacher-hiring practices, and the court further found that the small number of black teachers employed by the District was not probative of discrimination because of the proportionately small number of black students in the District. The appellate court reversed and entered judgment in favor of the United States, concluding that the statistical disparity between the number of black teachers in the District and the number of black teachers in the surrounding districts, bolstered by additional evidence of discrimination, made a prima facie showing of discrimination that was not rebutted by the District. The United States Supreme Court granted certiorari.