Locke v. Kansas City Power & Light Co.

Julius Locke (plaintiff), a Black man, was a temporary employee at Kansas City Power & Light Company (company) (defendant). Locke applied for a permanent plant-helper position, but the company refused to hire him for the position. Instead, the company hired three White temporary employees as permanent plant helpers. Locke brought suit, alleging that the company racially discriminated against him in violation of Title VII of the Civil Rights Act of 1964 (Title VII). The district court found that the company violated Title VII by denying Locke a permanent plant-helper position. In fashioning an equitable remedy, the district court sought to put Locke in the position he would have occupied in the absence of discrimination. Because the White temporary employees hired in place of Locke had all been promoted from plant-helper to relief-man positions, the district court ruled that Locke also was entitled to a relief-man position. Thus, although Locke was denied employment as a plant helper, the district court ordered that Locke be instated in the higher-level position of relief man. The district court did not determine whether Locke was qualified for a relief-man position. Also, the district court did not determine whether a plant helper would normally be promoted to relief man after some period of acceptable performance as a plant helper. The company appealed.