Ricci v. DeStefano

Ricci v. DeStefano, 557 U.S. 557 (2009), is a United States labor law case of the United States Supreme Court on unlawful discrimination through disparate impact under the Civil Rights Act of 1964.

Twenty city firefighters at the New Haven Fire Department, nineteen white and one Hispanic, passed the test for promotion to a management position, yet the city declined to promote them because none of the black firefighters who took the same test scored high enough to be considered for promotion. New Haven officials invalidated the test results because they feared a lawsuit over the test's disproportionate exclusion of a certain racial group (blacks) from promotion under a disparate impact cause of action. The twenty non-black firefighters claimed discrimination under Title VII of the Civil Rights Act of 1964.

The Supreme Court held 5–4 that New Haven's decision to ignore the test results violated Title VII because the city did not have a "strong basis in evidence" that it would have subjected itself to disparate impact liability if it had promoted the white and Hispanic firefighters instead of the black firefighters. Because the plaintiffs won under their Title VII claim, the Court did not consider the plaintiffs' argument that New Haven violated the constitutional right to equal protection.

Facts

In late 2003, the New Haven Fire Department had seven openings for captain and eight openings for lieutenant. To fill the open positions, it needed to administer civil service examinations. The examinations consisted of two parts: a written examination and an oral examination.