FIRAC Method

HAZELWOOD SCHOOL DISTRICT v. UNITED STATES No 76-255
Facts: The US Attorney General brought charges against Hazelwood School District citing that the school had a habit of discriminating against African-Americans when hiring teachers. According to him, this breached Title VII of the Civil Rights Act of 1964. The government presented statistical evidence that indicated the number of African Americans employed. The district court ruled in favor of Hazelwood , affirming that the evidence provided did not show a practice of prejudice. The US court of Appeals reversed this judgment.
Issue: did the lower court act in error when it decided to rule in favor of Hazelwood?
Rule: Statistics can be a vital source of proof especially in cases that pertain to employment discrimination. Where gross statistical differences can be demonstrated, they solely may in a proper case amount to prima facie proof of a practice or pattern of discrimination. It is normally to be anticipated that non-bias hiring practices will in time lead to a labor force more or less representative of the ethnic and racial composition of the population, although Title VII compels no requirement that a labor force reflects the general population.
Analysis: Yes. The lower court erred when it ruled in favor of Hazelwood. This is because it erred in establishing the pertinent labor market. This court also failed to put into consideration that Hazelwood may have been able to disprove some of the statistics with evidence of its practices of hiring post Title VII.
Conclusion: The finding of the court was mainly founded on statistical evidence that the government introduced demonstrating a comparison of the proportion of black Americans on Hazelwood’s teaching personnel with the proportion of teachers in the region who were African Americans instead of the percentage of black American pupils in Hazelwood District. The fairly small proportion of back American teachers that Hazelwood had employed when coupled with the proof presented by the government prompted the court of appeals to rule against Hazelwood.