Hazelwood School District v. United States

Hazelwood School District v. United States (1977) involved a dispute over inequitable hiring practices involving African American teachers. In Hazelwood, the U.S. Supreme Court held that in order to determine whether a school board and educational officials engaged in a discriminatory pattern or practice of underemploying African American teachers, the judiciary had to undertake a comparison between the percentage of African American teachers in the district and the percentage of African American teachers in the labor market of the surrounding area.

Facts of the Case

Hazelwood began when the U.S. government filed suit against the Hazelwood School District, in St. Louis County, Missouri, and various educational officials, alleging that they had violated Title VII of the Civil Rights Act of 1964 and the Fourteenth Amendment’s dictate that public employers not engage in purposeful racial discrimination. Title VII prohibits governmental and other employers from engaging in workplace discrimination based on race, color, religion, gender, or national origin.

At issue in Hazelwood was whether the board and school officials discriminated against African American applicants in their hiring practices. In response to these inequities, the federal government sought an injunction demanding that the board stop its discriminatory practices, that the board and its officials take steps to hire more African Americans, and that the board offer positions and back pay to the African American victims who had been discriminated against by the past employment practices.

A federal trial court in Missouri dismissed in favor of the board in asserting that since the government failed to established the necessary “pattern or practice” of racial discrimination, there was no violation of Title VII present. Yet the Eighth Circuit reversed and remanded in finding that the trial court relied on the incorrect comparison between African American teachers and African American students in the district. Instead, the appellate panel pointed out that the trial court should have relied on a comparison between the number of African American teachers that the board employed and the total accounting of African American teachers in the labor market of the surrounding area.

To this end, the court maintained that the relevant labor market should have included both St. Louis County and the city of St. Louis. Using this definition, the court observed that the total population of African American teachers in the labor market was 15.4%. Insofar as this percentage was considerably different from the actual percentage of African American teachers that the board had hired, which ranged from 1.4% to 1.8%, the court decided that the board had engaged in a pattern or practice of racial discrimination. In other words, the court was satisfied that the government presented enough evidence, based on the statistical disparity and past hiring practices, that the board had violated Title VII.

The Court’s Ruling

Disagreeing with the calculation that the government used to illustrate its underemployment of African American teachers, the school board appealed to the Supreme Court. Specifically, the board argued that the government’s statistical evidence was unfairly skewed because it included data from the city of St. Louis, which set a goal of maintaining a 50% ratio of African American teachers.

On further review, the Supreme Court affirmed that the Eighth Circuit correctly compared the number of African American employees in the school district with the number in the surrounding labor market. At the same time, though, the Court was of the opinion that the Eighth Circuit incorrectly calculated the statistical data because it did not take into account the data that were available once the board was subject to Title VII, namely after March 24, 1972.

Put another way, the Court reasoned that in order for the board to have been liable for having violated Title VII, the pattern or practice of discrimination must have occurred after it was subject to the statute. Accordingly, the Court remanded Hazelwood for a consideration of how the relevant labor market of African American teachers should have been calculated and whether there was a pattern or practice of employment discrimination after March 24, 1972. In its rationale, the Justices instructed the trial court to use data based on the time frame between 1972 and 1974, which showed that 3.7% of the teachers hired in the school system had been African Americans.

Justice Brennan concurred in reiterating the significance of how the statistical data were calculated. However, Justice Stevens dissented on the basis that the government had presented substantial evidence to conclude that the board had engaged in a pattern or practice of racial discrimination. Accordingly, he would have affirmed the judgment of the Eighth Circuit.

Janet R. Rumple

See also Civil Rights Act of 1964; Title VII

Legal Citations

  • Hazelwood School District v. United States, 433 U.S. 299 (1977). 
  • Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e.