Washington v. Davis
Headline: Ruling allows police department to keep a neutral entrance exam, saying racial score differences alone do not prove constitutional discrimination without proof of discriminatory intent, affecting job applicants and hiring rules nationwide.
Holding: The Court held that the Constitution does not forbid a facially neutral hiring test that has a disparate racial impact unless the government acted with a discriminatory purpose, and it reversed the appeals court to uphold Test 21.
- Allows government agencies to use neutral qualifying tests despite disparate racial outcomes absent discriminatory intent.
- Makes it harder for applicants to challenge tests based only on statistical disparities.
- Affirms that training-related test validation can justify use of an entrance exam.
Summary
Background
Two Black applicants and other intervenors challenged the District of Columbia Metropolitan Police Department’s use of Test 21 after they were rejected, saying the written exam excluded a disproportionately high number of Black applicants. Test 21 was developed by the Civil Service Commission, measures verbal and reading skills, and was required for entry into a 17-week police training program. The District Court upheld the test; the Court of Appeals invalidated it because of its unequal racial impact, and the case reached the Supreme Court.
Reasoning
The Court asked whether a facially neutral hiring test that has a disparate racial impact violates the Constitution by itself. The majority held that constitutional equal-protection principles require proof of a discriminatory purpose, not just a statistical disparity. The Court agreed with the District Court that Test 21 was reasonably related to the training program and that the Department’s active recruitment of Black applicants and changing recruit composition undercut any inference of purposeful discrimination.
Real world impact
The decision lets government employers continue to use neutral qualifying tests even when scores show racial differences unless plaintiffs prove intentional discrimination. The Court also accepted that showing a test predicts success in job-related training can validate its use, and it said any remaining statutory issues under employment laws should be addressed through those statutory procedures.
Dissents or concurrances
A concurring Justice agreed with the result but emphasized narrower grounds and deference to trial factfinding. A dissent argued the Court should not have decided statutory questions and would have required closer proof tying the test to actual job performance.
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