Pullman-Standard v. Swint

Citation. 456 U.S. 273 (1982)

Brief Fact Summary.

Respondents sued Petitioners for violating Title VII.

Synopsis of Rule of Law.

Rule 52(a) requires that a district court’s finding of fact not be set aside unless clearly erroneous.

Facts.

Black employees (Respondents) sued their employer, Pullman-Standard (Petitioner), and their unions, United Steelworkers of America, AFL-CIO-CLC, Local 1466 (Petitioners), arguing that their seniority system violated Title VII.

Issue.

Did the Court of Appeals apply the correct standard under Rule 52(a) when reviewing the District Court’s determination that the seniority system was not intentionally discriminatory?

Held.

No, the Court of Appeals improperly set aside the District Court’s findings of fact without a determination of clear error. The decision of the Court of Appeals is reversed and remanded.

Dissent.

Justice Marshall

Justice Marshall argued that it was proper for the Court of Appeals to review the documentary evidence without deference to the District Court.

Discussion.

The Court determined that the question of whether or not the seniority system was intentionally discriminatory was a finding of fact not a legal presumption. The Court relied on precedent that treated issues of intent as factual and subject to review under the clearly erroneous standard of Rule 52(a). Though the Court of Appeals said that it reviewed the District Court’s decision for clear error, it reversed the decision based on its own interpretation of the facts and not a finding of an erroneous view of the law.