## Facts

- Minority firefighters, through an organization, filed a federal class action alleging that the City of Cleveland’s fire department engaged in race and national-origin discrimination in hiring, assignments, and promotions, violating Title VII and other laws.
- The City negotiated a settlement with the minority firefighters that included a consent decree providing race-conscious promotional goals and related affirmative measures, including increasing supervisory positions.
- The firefighters’ union, representing a majority of firefighters, intervened and objected, arguing the decree would harm members’ interests in seniority, examinations, and promotion opportunities.
- After an initial version was rejected by union membership, the City and the minority firefighters submitted an amended decree that did not require union approval.
- The district court entered the consent decree over the union’s objections; the court of appeals affirmed.

## Issues

1. Whether Title VII § 706(g) bars entry of a consent decree providing race-conscious promotional relief that may benefit individuals not adjudicated to be discrimination victims.
2. Whether an intervenor may block a proposed consent decree by withholding consent or by requiring that the decree be limited to relief a court could order after a full trial.
3. Whether Title VII permits parties to adopt reasonable race-conscious relief as part of voluntary settlement embodied in a judicially entered consent decree.

## Decision

- The Supreme Court affirmed the approval and entry of the consent decree.
- Section 706(g) did not preclude the consent decree’s race-conscious provisions, even if they could benefit individuals who were not proven victims of discrimination.
- An intervenor is entitled to participate, present objections, and appeal, but does not have authority to veto settlement between the original parties or force the decree to match the intervenor’s preferred trial outcome.

## Legal Principles

- Title VII favors voluntary compliance; employers and unions may voluntarily adopt reasonable race-conscious measures to remedy discrimination and conspicuous racial imbalance.
- The limitations in Title VII § 706(g) on what a court may order after trial do not, by themselves, restrict what parties may agree to in a voluntary consent decree.
- A consent decree is a hybrid of contract and judicial order; its obligations primarily arise from the parties’ agreement, and § 706(g)’s reference to “orders” does not categorically bar agreed-upon race-conscious relief.
- Intervention under Rule 24 allows a nonparty to protect its interests through participation and appeal, but does not confer a right to prevent the original parties from settling their dispute.
- An intervenor may challenge a decree as unlawful or unconstitutional, but cannot demand continuation of litigation to judgment simply because it objects to the settlement terms.

## Conclusion

The Court held that Title VII does not bar parties from settling discrimination claims through a consent decree that includes reasonable race-conscious promotional relief, and that an intervening union may object and appeal but cannot veto the settlement or require that the decree be limited to remedies a court could impose after trial.


Loc. No. 93, Int’l Ass’n of Firefighters, AFL-CIO v. City of Cleveland, 478 U.S. 501 (1986)