Hazelwood School District v. United States
United States Supreme Court
433 U.S. 299 (1977)
The United States (plaintiff) sued the Hazelwood School District (District) (defendant) in St. Louis County, Missouri, alleging a pattern of racially discriminatory teacher hiring under Title VII. The District's teaching staff was less than 2% Black between 1972 and 1974, compared to an average of 15.4% Black teachers in nearby districts (including the City of St. Louis, which maintained a 50% Black staffing policy). The District's hiring process gave principals broad, loosely supervised discretion. The district court found no pattern of discrimination, discounting the disparity because the District's student body was also predominantly white; the court of appeals reversed, holding the statistical comparison to surrounding districts established a prima facie case that the District failed to rebut, and entering judgment for the United States. The District sought review by the Supreme Court.
Whether a school district that discriminated in hiring before it became subject to Title VII may nonetheless rebut a plaintiff's prima facie statistical case of discrimination with additional evidence, and what the proper statistical comparison is for measuring such discrimination.