## Facts

- The United States sued a Missouri public school district and officials under Title VII, alleging a pattern or practice of racial discrimination in teacher hiring after Title VII began applying to public employers on March 24, 1972.
- Hazelwood School District is located in northern St. Louis County, Missouri, and hired teachers from the surrounding area.
- In the 1972–1973 and 1973–1974 school years, Black teachers comprised about 1.4% and 1.8% of Hazelwood’s teaching staff.
- The government relied primarily on statistical disparities between Hazelwood’s faculty and the pool of qualified Black teachers in the relevant labor market, and also presented numerous individual discrimination allegations.
- The district court entered judgment for Hazelwood, comparing Black teachers to Black students in the district and finding the showing insufficient.
- The Eighth Circuit reversed, holding that the proper comparison was faculty composition against the qualified teacher labor market (defined as St. Louis County plus the City of St. Louis) and treating the disparity as establishing a prima facie pattern-or-practice case.

## Issues

1. What statistical comparison and labor-market definition govern a prima facie pattern-or-practice case under Title VII for public-school teacher hiring.
2. How courts should treat pre-coverage data versus post-coverage data where Title VII became applicable to the employer on a specific date.
3. What rebuttal opportunity the employer must receive once the plaintiff establishes a prima facie case based on workforce statistics, including use of post-coverage hiring and applicant data.

## Decision

- The Supreme Court vacated the judgment of the court of appeals and remanded for further proceedings.
- The Court agreed that the proper statistical comparison is between the racial composition of the employer’s teaching staff and the racial composition of qualified teachers in the relevant labor market, not the student population.
- The Court held that the court of appeals erred by disregarding record evidence concerning Hazelwood’s hiring after March 24, 1972.
- The Court directed further factfinding on (1) the appropriate relevant labor market from which Hazelwood could reasonably be expected to draw teachers and (2) whether Hazelwood engaged in a pattern or practice of discrimination after Title VII coverage began.

## Legal Principles

- In Title VII pattern-or-practice litigation, a prima facie case may be established by substantial statistical disparities between an employer’s workforce and the qualified labor pool in the relevant labor market.
- The relevant labor market is a fact-dependent inquiry tied to the area from which the employer reasonably draws applicants; comparisons to a customer or student population are generally improper.
- Statistics supporting a prima facie case are rebuttable; the employer must have an opportunity to show that disparities reflect lawful, nondiscriminatory factors, including pre-coverage hiring patterns.
- When Title VII coverage begins on a specific date, liability must rest on post-coverage discrimination; pre-coverage data may provide context but cannot alone establish post-coverage liability.
- Post-coverage hiring and applicant-flow evidence may be probative both to support and to rebut an inference drawn from overall workforce composition.

## Conclusion

The Court required a labor-market comparison tied to qualified teachers and held that appellate review must account for post-coverage hiring evidence before sustaining a pattern-or-practice inference, vacating and remanding for labor-market factfinding and a post-March 24, 1972 discrimination determination.


Hazelwood Sch. Dist. v. United States, 433 U.S. 299 (1977)