Wards Cove Packing Co. v. Atonio

E165271

Wards Cove Packing Co. v. Atonio is a 1989 U.S. Supreme Court case that narrowed the standards for proving employment discrimination under Title VII, prompting Congress to later revise those standards in the Civil Rights Act of 1991.

All labels observed (3)

How this entity was disambiguated

Statements (46)

Predicate Object
instanceOf Title VII case ⓘ
United States Supreme Court case ⓘ
employment discrimination case ⓘ
citation 490 U.S. 642 ⓘ
congressionalResponse Several aspects of the decision were superseded by statute in the Civil Rights Act of 1991. ⓘ
court Supreme Court of the United States ⓘ
decisionDate 1989-06-05 ⓘ
dissentBy Harry A. Blackmun ⓘ
John Paul Stevens (in part) ⓘ
linked to: John Paul Stevens

Thurgood Marshall ⓘ
William J. Brennan, Jr. ⓘ
docketNumber 87-1387 ⓘ
effectOnLaw Narrowed the standards for proving disparate impact discrimination under Title VII prior to 1991. ⓘ
factualBackground Nonwhite workers were concentrated in unskilled cannery jobs while white workers held skilled and noncannery positions. ⓘ
fullCaseName Wards Cove Packing Co., Inc., et al. v. Atonio et al. ⓘ
holding In disparate impact cases under Title VII, the proper comparison is between the racial composition of the at-issue jobs and the racial composition of the qualified labor pool, not the employer’s total workforce. ⓘ
Once a plaintiff establishes a disparate impact, the employer’s burden is one of production to show a business justification, not a burden of persuasion. ⓘ
Plaintiffs in a disparate impact case must identify the specific employment practice that is challenged. ⓘ
Plaintiffs retain the ultimate burden of persuasion on the issue of whether a challenged practice is justified by business necessity. ⓘ
impact Shifted more of the burden in disparate impact cases onto plaintiffs until the 1991 amendments. ⓘ
industryContext Alaska salmon canning industry ⓘ
influenced Civil Rights Act of 1991 ⓘ
issue Whether statistical disparities in workforce composition alone established a prima facie case of disparate impact under Title VII. ⓘ
joinedByInMajority Anthony M. Kennedy ⓘ
Antonin Scalia ⓘ
John Paul Stevens (in part and in the judgment) ⓘ
Sandra Day O'Connor ⓘ
William H. Rehnquist ⓘ
jurisdiction United States ⓘ
legalArea civil rights law ⓘ
employment law ⓘ
labor law ⓘ
legalConcept burden of proof ⓘ
business necessity ⓘ
disparate impact ⓘ
legalProvision Title VII of the Civil Rights Act of 1964 ⓘ
majorityOpinionBy Byron R. White ⓘ
overruledByStatute Civil Rights Act of 1991 ⓘ
petitioner Wards Cove Packing Company, Inc. ⓘ
precedentStatus Partially superseded by statute but still cited for certain disparate impact principles. ⓘ
relatedCase Civil Rights Act of 1991 ⓘ
Griggs v. Duke Power Co. ⓘ
Watson v. Fort Worth Bank & Trust ⓘ
respondent Frank Atonio ⓘ
standardOfReview disparate impact analysis under Title VII ⓘ
timePeriod Rehnquist Court ⓘ

How these facts were elicited

Referenced by (7)

Full triples — surface form annotated when it differs from this entity's canonical label.

Civil Rights Act of 1991 → respondsToCourtDecision → Wards Cove Packing Co. v. Atonio ⓘ
Griggs v. Duke Power Co. → relatedCase → Wards Cove Packing Co. v. Atonio ⓘ
Wards Cove Packing Co. v. Atonio → fullCaseName → Wards Cove Packing Co., Inc., et al. v. Atonio et al. ⓘ
linked to: Wards Cove Packing Co. v. Atonio
Wards Cove Packing Co. v. Atonio → petitioner → Wards Cove Packing Company, Inc. ⓘ
linked to: Wards Cove Packing Co. v. Atonio
Public Law 102-166 → respondsTo → Wards Cove Packing Co. v. Atonio ⓘ
Frank Atonio → participantIn → Wards Cove Packing Co. v. Atonio ⓘ
Watson v. Fort Worth Bank & Trust → relatedTo → Wards Cove Packing Co. v. Atonio ⓘ