Dothard v. Rawlinson
United States Supreme Court
433 U.S. 321 (1977)
Rawlinson (plaintiff), a qualified applicant for an Alabama correctional counselor trainee position, was rejected solely for failing to meet a state statutory minimum weight requirement (paired with a height minimum) that also applied to all correctional counselor applicants; the district court found these combined requirements would exclude over 41% of the national female population but under 1% of the national male population, and found the State (defendant) failed to rebut Rawlinson's resulting prima facie case of sex discrimination under Title VII. The State appealed, arguing Rawlinson should have used statistics about actual Alabama applicants rather than national population data, and that it had shown the requirements were job-related.
Whether Title VII requires that a plaintiff's statistical showing of disparate impact be based on the characteristics of actual job applicants rather than the broader qualified population.