Watson v. Fort Worth Bank & Trust

Watson v. Fort Worth Bank & Trust, 487 U.S. 977 (1988), is a United States Supreme Court case on United States labor law, concerning proof of disparate treatment under the Civil Rights Act of 1964.

Facts

Plaintiff Watson, an African-American bank teller, applied (on four separate occasions) for a promotion to a supervisory position at the bank.

The bank had not developed precise and formal selection criteria for the positions in question, but instead relied upon the subjective judgment of supervisors who were acquainted with the candidates and the nature of the jobs to be filled.

In all four instances, the supervisors involved in the promotion process were white, and all four times Watson was not selected.

After exhausting her administrative remedies before the Equal Employment Opportunity Commission, Watson filed suit in the United States District Court for the Northern District of Texas. She included allegations that the bank's promotion policies discriminated both against blacks as a class and against her individually, in violation of Title VII of the Civil Rights Act of 1964 (42 USCS 2000e et seq.).

After trial, the District Court, dismissing the teller's individual claims, found that she had failed to make a sufficient showing under applicable evidentiary standards. The United States Court of Appeals for the Fifth Circuit affirmed in relevant part, and expressed the view that the proper framework to apply to a Title VII challenge to an allegedly discretionary promotion system would be disparate treatment analysis (which involves the question whether an employer has, with a discriminatory intent or motive, treated a particular person less favorably than others because of that person's race, color, religion, sex, or national origin) rather than disparate impact analysis (which involves the question whether an employer has engaged in facially neutral employment practices that have significant adverse effects on protected groups, and which usually, in the absence of proof that the employer adopted such practices with a discriminatory intent, focuses on statistical disparities)

Judgment

On certiorari, the United States Supreme Court vacated the judgment of the Court of Appeals and remanded the case for further proceedings.

Seven members of the Court (1) agreed that disparate impact analysis may be applied to allegedly discriminatory subjective or discretionary employment practices, and (2) agreed regarding certain aspects of the evidentiary standards applicable in such cases.