Watson v. Fort Worth Bank & Trust

Watson (plaintiff), a Black bank employee, was repeatedly passed over for supervisory promotions in favor of white candidates, with the bank's (defendant) supervisors making promotion decisions based entirely on their own subjective judgment rather than any formal or standardized criteria; Watson sued alleging the bank's informal, discretionary promotion practice produced a disparate racial impact violating Title VII, and the lower courts rejected her claim, apparently reasoning disparate-impact analysis did not extend to subjective decisionmaking.