42 U.S.C. § 1981 covers discrimination in the making and enforcement of contracts, but not conduct by the employer after the contract relation has been established
E642305
Patterson v. McLean Credit Union is a 1989 U.S. Supreme Court decision that narrowly interpreted 42 U.S.C. § 1981 to apply only to racial discrimination in the formation and enforcement of contracts, excluding most post-formation employment discrimination claims.
All labels observed (1)
How this entity was disambiguated
This entity first appeared as the object of triple T7093937 — resolving that mention is where its identity was fixed. The disambiguator weighed these candidate entities and picked the highlighted one (or “None”, minting a new entity). This is how homonymy is resolved: the same surface form can point to different entities.
NED1
Entity disambiguation (via context triple)
gpt-5-mini-2025-08-07
Target entity: 42 U.S.C. § 1981 covers discrimination in the making and enforcement of contracts, but not conduct by the employer after the contract relation has been established Context triple: [Patterson v. McLean Credit Union, holding, 42 U.S.C. § 1981 covers discrimination in the making and enforcement of contracts, but not conduct by the employer after the contract relation has been established]
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A.
Title VII of the Civil Rights Act of 1964
Title VII of the Civil Rights Act of 1964 is a landmark U.S. federal law that prohibits employment discrimination based on race, color, religion, sex, or national origin.
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B.
Title II of the Civil Rights Act of 1964
Title II of the Civil Rights Act of 1964 is a landmark federal law that prohibits discrimination on the basis of race, color, religion, or national origin in places of public accommodation such as hotels, restaurants, and theaters.
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C.
Title X of the Civil Rights Act of 1964
Title X of the Civil Rights Act of 1964 is the section of the landmark federal civil rights law that establishes the Community Relations Service to help communities resolve disputes and tensions arising from discriminatory practices.
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D.
Title VII
Title VII is a section of the Improving America’s Schools Act of 1994 that focuses on providing federal support to improve educational opportunities, particularly for disadvantaged and underserved student populations.
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E.
Title VII
Title VII is a section of the Education Amendments of 1972 that addresses specific federal policies related to education, distinct from the better-known Title IX provisions on sex discrimination.
- F. None of above. chosen
- G. Unsure - the case is ambiguous/there is not enough information to decide.
NED2
Entity disambiguation (via description)
gpt-5-mini-2025-08-07
Target entity: 42 U.S.C. § 1981 covers discrimination in the making and enforcement of contracts, but not conduct by the employer after the contract relation has been established Target entity description: Patterson v. McLean Credit Union is a 1989 U.S. Supreme Court decision that narrowly interpreted 42 U.S.C. § 1981 to apply only to racial discrimination in the formation and enforcement of contracts, excluding most post-formation employment discrimination claims.
-
A.
Title VII of the Civil Rights Act of 1964
Title VII of the Civil Rights Act of 1964 is a landmark U.S. federal law that prohibits employment discrimination based on race, color, religion, sex, or national origin.
-
B.
Title II of the Civil Rights Act of 1964
Title II of the Civil Rights Act of 1964 is a landmark federal law that prohibits discrimination on the basis of race, color, religion, or national origin in places of public accommodation such as hotels, restaurants, and theaters.
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C.
Title X of the Civil Rights Act of 1964
Title X of the Civil Rights Act of 1964 is the section of the landmark federal civil rights law that establishes the Community Relations Service to help communities resolve disputes and tensions arising from discriminatory practices.
-
D.
Title VII
Title VII is a section of the Improving America’s Schools Act of 1994 that focuses on providing federal support to improve educational opportunities, particularly for disadvantaged and underserved student populations.
-
E.
Title VII
Title VII is a section of the Education Amendments of 1972 that addresses specific federal policies related to education, distinct from the better-known Title IX provisions on sex discrimination.
- F. None of above. chosen
Statements (41)
| Predicate | Object |
|---|---|
| instanceOf |
United States Supreme Court case
ⓘ
judicial decision ⓘ |
| appliesStatute | 42 U.S.C. § 1981 ⓘ |
| areaOfLaw |
civil rights law
ⓘ
employment discrimination law ⓘ |
| citation | 491 U.S. 164 ⓘ |
| country |
United States
ⓘ
linked to:
United States of America
|
| court | Supreme Court of the United States ⓘ |
| decisionDate | 1989 ⓘ |
| decisionType | narrow interpretation of 42 U.S.C. § 1981 ⓘ |
| effect |
limited the scope of federal remedies for post-formation employment discrimination under 42 U.S.C. § 1981
ⓘ
prompted congressional response in the Civil Rights Act of 1991 ⓘ |
| factPattern | African American employee alleged racial harassment and discriminatory failure to promote ⓘ |
| holding |
42 U.S.C. § 1981 covers racial discrimination in the making and enforcement of contracts
ⓘ
42 U.S.C. § 1981 does not generally cover conduct by the employer after the contract relation has been established ⓘ post-formation employment discrimination claims are largely outside the scope of 42 U.S.C. § 1981 ⓘ racial harassment in the workplace is not actionable under 42 U.S.C. § 1981 when it concerns post-formation conduct ⓘ |
| influencedBy | textual interpretation of 42 U.S.C. § 1981 ⓘ |
| interprets | "make and enforce contracts" language in 42 U.S.C. § 1981 ⓘ |
| issue |
scope of 42 U.S.C. § 1981 in employment discrimination cases
ⓘ
whether racial harassment and discriminatory working conditions are actionable under 42 U.S.C. § 1981 ⓘ |
| jurisdiction | United States federal law ⓘ |
| keyPhraseInterpreted | "make and enforce contracts" in 42 U.S.C. § 1981 ⓘ |
| language | English ⓘ |
| legalCitation | 491 U.S. 164 (1989) ⓘ |
| legalPrinciple | section 1981 protects the right to make and enforce contracts, not conditions of continuing employment ⓘ |
| legalStatusAfter1991 | partially superseded by statute ⓘ |
| majorityOpinionBy | William H. Rehnquist ⓘ |
| overruledInPartBy | Civil Rights Act of 1991 ⓘ |
| petitioner | Brenda Patterson ⓘ |
| precedentFor | limiting section 1981 to contract formation and enforcement prior to 1991 amendments ⓘ |
| relatedCase |
Goodman v. Lukens Steel Co.
ⓘ
Runyon v. McCrary ⓘ |
| relatedConcept |
post-formation employment discrimination
ⓘ
racial discrimination in contracting ⓘ workplace racial harassment ⓘ |
| relatedLegislation | Civil Rights Act of 1991 ⓘ |
| respondent | McLean Credit Union ⓘ |
| result | judgment largely limiting section 1981 claims to contract formation and enforcement ⓘ |
| subsequentDevelopment | Congress amended 42 U.S.C. § 1981 to cover post-formation conduct ⓘ |
| topic | interpretation of Reconstruction-era civil rights statutes ⓘ |
How these facts were elicited
The pipeline generated the facts above by prompting gpt-5.1 with this entity's name + description and the instruction below.
Instruction
You are a knowledge base construction expert. Given a subject entity and a description of it, return factual statements that you know for the subject as a JSON list of dictionaries(triples), where keys must be "subject", "predicate" and "object". The number of facts may be very high, between 25 to 50 or more, for very popular subjects. For less popular subjects, the number of facts can be very low, like 5 or 10. # Requirements - If you don't know the subject at all, return an empty list. - If the subject is not a named entity, return an empty list. - Include at least one triple where predicate is "instanceOf". - Do not get too wordy. - Separate several objects into multiple triples with one object.
Input
Subject: 42 U.S.C. § 1981 covers discrimination in the making and enforcement of contracts, but not conduct by the employer after the contract relation has been established Description of subject: Patterson v. McLean Credit Union is a 1989 U.S. Supreme Court decision that narrowly interpreted 42 U.S.C. § 1981 to apply only to racial discrimination in the formation and enforcement of contracts, excluding most post-formation employment discrimination claims.
Referenced by (1)
Full triples — surface form annotated when it differs from this entity's canonical label.
Patterson v. McLean Credit Union
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holding
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42 U.S.C. § 1981 covers discrimination in the making and enforcement of contracts, but not conduct by the employer after the contract relation has been established
ⓘ