Landmark Judgments On Workplace Discrimination
1. Griggs v. Duke Power Co. (1971)
Jurisdiction: United States Supreme Court
Facts:
Duke Power Company required a high school diploma and passing two aptitude tests for certain jobs. However, these requirements disproportionately disqualified African-American applicants, even though the tests were not clearly related to job performance.
Issue:
Whether the employment requirements, which seemed neutral on their face but disproportionately excluded minorities, violated Title VII of the Civil Rights Act of 1964.
Holding:
The Court held that employment practices that disproportionately impact minorities must be related to job performance. This case established the principle of “disparate impact” discrimination, meaning that even neutral policies can be illegal if they disproportionately affect a protected group without being job-related.
Significance:
Griggs set a precedent that employers must justify employment tests or requirements that result in racial disparities. It broadened protection against workplace discrimination beyond intentional discrimination to include policies with unjustified adverse impacts.
2. Price Waterhouse v. Hopkins (1989)
Jurisdiction: United States Supreme Court
Facts:
Ann Hopkins, a senior manager at Price Waterhouse, was denied partnership partly because she did not conform to traditional female gender norms—she was told to dress and behave more femininely.
Issue:
Whether discrimination based on gender stereotypes constituted sex discrimination under Title VII.
Holding:
The Court ruled that discrimination based on gender stereotypes is unlawful sex discrimination. Hopkins was denied partnership due to bias about how women should behave, which violates Title VII.
Significance:
This case expanded the understanding of sex discrimination to include not just disparate treatment based on gender but also discrimination based on failure to conform to gender stereotypes.
3. Vishaka v. State of Rajasthan (1997)
Jurisdiction: Supreme Court of India
Facts:
Bhanwari Devi, a social worker, was sexually assaulted in a rural area, and the authorities failed to provide justice. This case was used to address the absence of legal provisions against sexual harassment at workplaces in India.
Issue:
The lack of specific laws addressing sexual harassment of women at workplaces and how to protect women's fundamental rights.
Holding:
The Supreme Court laid down the Vishaka Guidelines, which imposed duties on employers to prevent sexual harassment at the workplace. The guidelines recognized sexual harassment as a violation of women's fundamental rights to equality, dignity, and safe working conditions under Articles 14, 15, and 21 of the Indian Constitution.
Significance:
This judgment was a watershed moment in India, as it was the first time the judiciary laid down detailed directions to protect women against workplace sexual harassment, leading to the enactment of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013.
4. McDonnell Douglas Corp. v. Green (1973)
Jurisdiction: United States Supreme Court
Facts:
Green, an African-American employee, was laid off during a reduction in force but alleged that his dismissal was due to racial discrimination because he was involved in civil rights protests.
Issue:
How to prove discrimination when there is no direct evidence of discriminatory intent.
Holding:
The Court established a burden-shifting framework for discrimination cases when there is no direct evidence:
The plaintiff must establish a prima facie case of discrimination.
The employer must then articulate a legitimate, non-discriminatory reason for the adverse action.
The plaintiff must then show that the employer's reason is a pretext for discrimination.
Significance:
This framework remains a foundational tool in discrimination litigation, guiding how courts evaluate evidence and arguments in employment discrimination claims.
5. Faragher v. City of Boca Raton (1998)
Jurisdiction: United States Supreme Court
Facts:
Faragher, a lifeguard supervisor, sued the city for sexual harassment by her supervisors.
Issue:
Whether an employer is liable for the harassing behavior of its employees, and what defenses are available.
Holding:
The Court ruled that employers are vicariously liable for supervisors’ harassment if it results in a hostile work environment. However, employers can avoid liability if they can prove:
They exercised reasonable care to prevent and promptly correct harassment.
The employee unreasonably failed to take advantage of preventive or corrective opportunities.
Significance:
This case clarified employer liability and established standards for preventing and responding to workplace harassment.
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