Cooper v. Federal Reserve Bank of Richmond

Background

The Equal Employment Opportunity Commission sued a Federal Reserve Bank branch in Charlotte, alleging racial employment practices. Four employees intervened and a class of black employees was certified for claims since January 3, 1974. The district court found a pattern of discrimination only in pay grades 4 and 5, sent notice to class members who were told they would be bound unless they opted out, and some class members, including the Baxter group, did not exclude themselves.

Reasoning

The Court addressed whether a class judgment finding no companywide pattern of discrimination prevents class members from later bringing their own individual claims. The Justices explained that a class finding about general policies focuses on companywide proof, while an individual claim focuses on the reason for a single promotion decision. A class loss on the pattern question bars relitigation of that pattern claim but does not decide the separate question of what motivated an individual hiring or promotion decision.

Real world impact

The ruling means workers who stayed in a class can still sue separately about their own promotions if they make the usual prima facie showing. A prior class finding that there was no general policy may be used as evidence on motive, but it does not automatically end an employee’s individual case. The Court reversed the appeals court and sent the cases back for further proceedings.