Brief Fact Summary. A higher percentage of black applicants than white applicants failed a qualifying test administered by the District of Columbia Police Department. Some of the unsuccessful black applicants claimed these effects constituted unconstitutional discrimination against them.
Synopsis of Rule of Law. Proof of a disproportionate impact is not enough, standing alone, to ground a finding that a law amounts to unconstitutional discrimination.
Issue. Was proof of the disproportionate effects of the qualifying exam sufficient to ground a finding that the exam unconstitutionally discriminated against the respondents?
Held. No. The Court of Appeals, reversing the District Court, is reversed.
Justice Byron White (J. White) said our cases have not embraced the proposition that a law can be a violation of equal protection on the basis of its effect, without regard for governmental intent. Disproportionate impact is not irrelevant, but it alone does not trigger the rule that racial classifications are subject to the strict scrutiny standard of review. The police force’s efforts to recruit black police officers are evidence that the police department did not intentionally discriminate on the basis of race.
The exam is rationally related to the legitimate government purpose of ensuring that police officers have acquired a particular level of verbal skill.
Concurrence. Justice John Paul Stevens (J. Steven) said that frequently the most probative evidence of intent will be a showing of what actually happened. A Constitutional issue does not arise, however, every time some disproportionate impact is shown.
Discriminatory tests are impermissible unless shown, by professionally acceptable methods, to be predictive of or significantly correlated with important elements of work behavior which comprise or are relevant to the job or jobs for which candidates are being evaluated.View Full Point of Law