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Hazelwood School District v. United States

United States Supreme Court
433 U.S. 299 (1977)


Facts

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, located in St. Louis County, Missouri, was formed between 1941-51 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 3 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. The black teachers in the surrounding school districts. 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 court of appeals concluded that this statistical disparity, bolstered by additional evidence of discrimination, made a prima facie showing of discrimination that was not rebutted by the District. It entered judgment for the United States. The District petitioned for review by the United States Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Stewart, J.)

Concurrence (White, J)

Dissent (Stevens, J.)

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