## Facts

- The United States sued T.I.M.E.–D.C., Inc. (a nationwide motor-freight carrier) and the International Brotherhood of Teamsters under Title VII on behalf of Black and Spanish-surnamed employees.
- The Government alleged minorities were disproportionately hired or assigned to lower-paying serviceman and city-driver jobs and were denied access to higher-paying line-driver positions.
- The Government supported its claims with statistical disparities in line-driver hiring and additional testimony describing multiple discriminatory incidents.
- Collective-bargaining agreements maintained separate seniority systems for different job classifications; transferring into line-driver work required forfeiting accumulated competitive seniority and starting at the bottom of the line-driver seniority board.
- The Government argued the seniority structure perpetuated earlier discrimination by discouraging minority transfers through severe seniority penalties.
- After a bench trial, the district court found Title VII violations and entered broad injunctive and individual relief, defining an “affected class” that included minority city drivers and servicemen across terminals and allowing transfers with full company seniority and preference for line-driver openings.
- The court of appeals largely affirmed the liability findings but modified aspects of the remedy.
- The Supreme Court reviewed issues involving systemwide discrimination, the status of the seniority system under Title VII, and the proper scope of relief.

## Issues

1. Whether the Government proved a systemwide pattern or practice of discrimination in hiring, assignment, and promotion in violation of Title VII § 703(a).
2. Whether a facially neutral seniority system that perpetuates pre-Title VII effects is protected as a bona fide system under Title VII § 703(h) absent discriminatory intent.
3. What burden-shifting and individualized proof rules govern relief in a pattern-or-practice case, including whether nonapplicants may obtain relief when applying would have been futile.

## Decision

- The Court held the Government proved a pattern or practice of discrimination by the employer against minority employees.
- The Court held the seniority system was bona fide and protected by § 703(h) because it was facially neutral and not adopted or maintained with discriminatory intent, even if it carried forward effects of pre-Act discrimination.
- The Court adopted a pattern-or-practice framework: after the Government proves a discriminatory policy, individual employment decisions during the relevant period are presumptively discriminatory unless the employer shows lawful reasons as to particular individuals.
- The Court limited broad classwide seniority remedies and required individualized determinations that a person would have obtained the desired position but for post-Act discrimination.
- The Court recognized that failure to apply does not bar relief where discriminatory practices effectively deterred applications and an application would have been futile.

## Legal Principles

- A Title VII “pattern or practice” is shown when discrimination is the employer’s regular practice rather than isolated events; statistical proof, supported by testimonial evidence, can establish the prima facie case.
- Once a pattern or practice is established, the burden shifts to the employer to prove that a challenged decision affecting a particular person was made for lawful reasons.
- Title VII § 703(h) protects a bona fide seniority system that is facially neutral and not the product of intentional discrimination, even if it perpetuates effects of discrimination occurring before Title VII became effective.
- Title VII does not impose liability merely for the continuing consequences of pre-Act discrimination; remedial relief must be tied to unlawful post-Act discrimination.
- Nonapplicants may obtain relief if they show they were deterred by discriminatory practices such that applying would have been a useless act.

## Conclusion

The Court upheld liability for systemwide discrimination under Title VII while protecting a facially neutral, non-intentionally discriminatory seniority system under § 703(h), and it clarified that pattern-or-practice proof shifts burdens for individual relief but requires individualized showings tied to post-Act discrimination, including relief for deterred nonapplicants under a futility theory.


Int'l Bhd. of Teamsters v. United States, 431 U.S. 324 (1977)