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Originally Processed With FOIA(s): FOIA Number: S; 1999-0285-F S FOIA MARKER This is not a textual record. This is used as an administrative marker by the George Bush Presidential Library Staff. Record Group/Collection: George H.W. Bush Presidential Records Collection/Office of Origin: Speechwriting, White House Office of Series: Speech File Backup Files Subseries: Chron File, 1989-1993 OA/ID Number: 13719 Folder ID Number: 13719-006 Folder Title: U.S. Civil Rights Members' Swearing-in 5/17/90 [OA 6898] [2] Stack: Row: Section: Shelf: Position: G 26 20 5 7 Withdrawal/Redaction Sheet (George Bush Library) Document No. Subject/Title of Document Date Restriction Class. and Type 01. Speech draft Presidential Remarks: National Commission on Civil Rights, 05/14/90 Thursday, May 17, 1990 (9 pp.) Collection: Record Group: Bush Presidential Records Open on Expiration of PRA Office: Speechwriting, White House Office of (Document Follows) Series: Speech File, Backup Files By MM (NLGB) on 01/19/2009 Subseries: Chron File, 1989-1993 WHORM Cat.: File Location: Speech File Backup Files U.S. Civil Rights Members' Swearing-In, 5/17/90 [2] [OA/ID 06898] Date Closed: OA/ID Number: 13719-006 FOIA/SYS Case #: Appeal Case #: Re-review Case #: Appeal Disposition: P-2/P-5 Review Case #: Disposition Date: AR Case #: MR Case #: AR Disposition: MR Disposition: AR Disposition Date: MR Disposition Date: RESTRICTION CODES Presidential Records Act - [44 U.S.C. 2204(a)] Freedom of Information Act - [5 U.S.C. 552(b)] P-1 National Security Classified Information [(a)(1) of the PRA] (b)(1) National security classified information [(b)(1) of the FOIA] P-2 Relating to the appointment to Federal office [(a)(2) of the PRA] (b)(2) Release would disclose internal personnel rules and practices of an P-3 Release would violate a Federal statute [(a)(3) of the PRA] agency [(b)(2) of the FOIA] P-4 Release would disclose trade secrets or confidential commercial or (b)(3) Release would violate a Federal statute [(b)(3) of the FOIA] financial information [(a)(4) of the PRA] (b)(4) Release would disclose trade secrets or confidential or financial P-5 Release would disclose confidential advice between the President information [(b)(4) of the FOIA] and his advisors, or between such advisors [a)(5) of the PRA] (b)(6) Release would constitute a clearly unwarranted invasion of P-6 Release would constitute a clearly unwarranted invasion of personal privacy [(b)(6) of the FOIA] personal privacy [(a)(6) of the PRA] (b)(7) Release would disclose information compiled for law enforcement purposes [(b)(7) of the FOIA] C. Closed in accordance with restrictions contained in donor's deed of (b)(8) Release would disclose information concerning the regulation of gift. financial institutions [(b)(8) of the FOIA] (b)(9) Release would disclose geological or geophysical information PRM. Removed as a personal record misfile. good but somethe eal in 0 say be Flarly: quotas ve are Nig wrong. where They or male ma seia Ameica Dear. (Lange/Cawley) May 14, 1990 11:30 A.M. [AFFIRM.DOC] PRESIDENTIAL REMARKS: NATIONAL COMMISSION ON CIVIL RIGHTS [ 450 OEOB ] THURSDAY, MAY 17, 1990 [ TIME ] Thank you all. Arthur Fletcher, Mary Frances Berry, Esther Gonzalez-Arroyo Buckley, Blandina Cardenas Ramirez, Russell Redenbauch; Dick Thornburg, Secretary Cavazos; Regional directors and State Advisory Committee Members It's an honor to have you here today. We meet on an auspicious day -- the anniversary of the landmark Brown V. Board of Education decision. And we meet at a very hopeful moment worldwide. A time when the thundering cry for freedom is being heard and answered from Johannesburg to Panama to Warsaw We cannot know how future generations will interpret this wondrous time. But if it fell to me to advise tomorrow's historians, I'd hope this might be known as a new age of freedom -- when the world was witness to the full deliverance of democracy's promise. Hopeful times, to be sure. But also hazardous -- as exciting and unsettling as the world has ever known Because the outcomes of this new age are not ordained -- they are ours to decide. Around the world, people wary of state control, economies are weary of bureaucratic central planning, all look ng to America as reason for hope -- the brighte star to follow as they chart their course to freedom. 2 So it's all the more crucial now, that we look carefully to the kind of country we are -- to the state of democracy here in Whatever the land of its birth. We are called upon to ensure that however about the nations of the world decide to make their futures, this democracy means opportunity, for all who call it home. No one in America -- no one -- has worked harder to deliver the promise of democracy, to make an enduring dream a living reality, than the men and women in this room today. From its earliest origins, the Commission on Civil Rights has been an independent, bipartisan voice for justice. The Commissioners, Directors, and volunteers who serve on Advisory Committees, all share an intellectual caliber, a moral conviction, and a cultural diversity that are truly America's best. These men and women have earned our admiration. Today, they deserve our thanks. [ In particular, I hope you'll join me in congratulating three new Commissioners: the new chairman, Arthur A. Fletcher; in absentia, Carl Anderson; and Russell G. Redenbaugh. ] Over the last few days I've met with leaders representing America's brilliant tapestry of cultural, religious, and ethnic rich diversity. I got, as I knew I would, a great deal of sound advice -- and as I imagined I would, just a little constructive criticism. But these leaders, this Commission, and this Administration, all share a common conviction, profoundly felt for equal opportunity. It's a responsibility I have always taken very 3 seriously -- and it's especially serious now, when our most vital export to the world is democracy. We must make sure that we as a nation lead by example. We must see that affirmative action is not reduced to a slogan -- and that the principle of equal opportunity has real, living meaning, for all Americans. My hope, as we begin the last decade of this century, is that the 1990's might be a more thoughtful decade an era more committed to community. I want Americans to think about the goals and values they share -- not the superficial distinctions and differences that divide them. The commonwealth and well-being of this nation have always relied on the strength of shared principles. Because behind the false barriers, beneath appearances, beyond the heat of politics, we all want the same things: A just society. Peace. Prosperity. A better life for our children than we've had for ourselves. So just as the world turns a hopeful face toward freedom, here at home we need a renewed sense that government exists to empower people. If America's best hope is the talent she's had all along, at every step in this evolving experiment we call democracy we should be asking ourselves, what are we doing and, does it work? To the Civil Rights leadership assembled here today: I have offered you my hand, and my word, that together we will make America "open and equal to all." Today I want to explore in greater depth our commitment to equal opportunity. are you insulting an Daniel X Entit Moynihan 4 To begin with, this administration is committed to action that is truly affirmative -- positive action, in every sense -- to strike down all barriers to advancement, of every kind, for all people. We will tolerate no barriers, no bias, no SO called 'benign neglect No inside tracks, no two-tiered systems, no glass ceilings, and no rungless ladders. \\ Now, let me tell you what we're against. \\ We're against any action or lack of action that would perpetuate or exacerbate injustice. And I know the leadership in the legislature Consums shares this conviction. This nation's progress against prejudice -- from the 1964 Civil Rights Act, to the Voting Rights Act, to the Fair Housing Act, to the Age Discrimination in Employment Act -- it has all hinged on the principle that no one in this country should be excluded from opportunity. That's why I remain firmly committed to the enactment this year of landmark legislation to extend protections to those Americans with disabilities. \\ And we're committed to new measures, like the Hate Crimes Statistics Act, fair housing initiatives, and revitalized enforcement of restrictions against employment bias. Perhaps softer this- males see like his goals we don't Many of this administration's proposals, in fact, share registration 100ml common ground goals with the legislation being offered by Senator Kennedy and Representative Hawkins. We've supported efforts to ensure an individual's ability to challenge discrimininatory seniority systems. We've also moved to stiffen the penalties for goals - define 5 racial discrimination in setting or applying the terms and conditions of employment. Today, as we work to ensure that America represents democracy's highest expression, I want to offer four principles that ought to inform guide any amendments to our civil rights laws. ? These principles are firmly rooted in the spirit of our current laws -- and after the extensive discussions we've had this week, I think they're principles on which we all of us -- including the leadership on the Hill -- can agree. So I will enthusiastically support legislation that meets these principles. First, civil rights legislation must operate to obliterate consideration of race, color, religion, sex, nation of origin, age, or disability from employment decisions. As you know, Title VII encourages hiring on the basis of ability and qualifications, not race or religion. Some provisions of the Kennedy-Hawkins bill, with the best of intentions, still have an unintended consequence: they encourage employers to make decisions on the basis of these irrelevant characteristics. In spite of recent amendments, the bill continues to encourage employers to base hiring decisions on the very considerations our civil rights laws direct them to red flag 3 consentives - ignore. this why elternive, not say nowless So we seek civil rights legislation that is more effective comprehensive, not less. Because the focus of employers in this country must be on providing equal opportunity for all workers 6 -- not on developing strategies for avoiding litigation -- strategies that are likely to result in quota schemes violating the most basic principles of our civil rights tradition, and the promise of democracy. The surest, most insidious symptom of the perpetuation of Neknewor injustice was well understood by Martin Luther King in 1962. when infact, American ofall he wrote, that "tokenism can now be seen not only as a useless walks of goal, but as a genuine menace. It is a palliative which relieves lifeknow today, a emotional distress, but leaves the disease and its ravages that grotas unaffected.' Asas are arearong. We want to eradicate the disease. And America's minority communities deserve more than symptomatic relief. They deserve systematic solutions -- through strategies that transcend statistics and quotas. Rather than perpetuate the demoralizing stigma of preferential distinctions, we should empower and ennoble our minority communities. Rather than sowing the seeds of self- doubt and questions of competence in anyone's heart, we should seek systematic change that allows every American to excel individually and as We should seek dignity without question marks or asterisks. Rather than asking statistics to be the arbiters of justice rather than dividing by group -- we should empower as a whole. And I'm confident the leadership will work with me to craft a bill, in the spirit of our record of unbiased civil rights legislation, that moves us toward this goal. 7 Second, civil rights legislation must reflect fundamental principles of fairness: individuals who believe their rights have been violated are entitled to their day in court, and an accused is innocent until proven quilty. In every case of civil rights dispute, constitutional protections must be preserved. e X There may be no raparation sufficient to the kind of injustice suffered through and still being overcome by America's minority communities. But the sense that this country recognizes past wrongs can, and must be matched with an equal determination to set them right We must hold ourselves to the highest standards and not let past injustice distort present potential and future achievements. The Constitution was written to protect the individual. And so must every one of us protect it. Third, Congress must subject itself to the same requirements it prescribes for others. In 1972, the Civil Rights Act of 1964 was justly applied to executive agencies and state and local governments. Congress, however, is not yet covered. This inconsistency must be remedied, to give Congressional employees and applicants the full protection of the law. These people, too, are entitled to their rights in court, and the Congress pin the Executive Bronch should be setting an example for employers in the private sector. And fourth, Federal law should provide an adequate + deterrence to sexual or religious harassment on the basis of disability in the workplace, and ensure a speedy end to such discriminatory practices. In improving the remedies, however, our civil rights laws should not be turned into a bonanza for 8 lawyers, encouraging litigation at the expense of conciliation, mediation, or settlement. Ultimately, cooperation will serve the interests of all parties far better than litigious conflicts. Arthur Fletcher said recently, "I'm looking for a more comprehensive response. You can't go a quarter-mile in this time in our nation's history when the full mile is needed." I agree. A moment ago, I spoke of my conviction that America's minority communities deserve more than symptomatic relief. I believe they deserve systematic solutions -- an agenda of change that transcends statistics and quotas. We seek strategies that work -- putting power where it belongs: in the hands of people. And that means new ideas, like school vouchers to give poor parents the power of an alternative, and choice in where to send their kids -- so that all can have access to the best. It means more tenant control and ownership of public housing. Tax credits for child care without restrictions of any kind, to give parents more flexibility and choice. And policies that underwrite prosperity, by encouraging capital flow to build more businesses in poor neighborhoods. Affirmative action and equal opportunity must be more than issues of social responsibility, and more than matters of legal compulsion. Because as labor markets tighten, people of every walk of life, of every kind, all will be in growing demand in this new decade. 9 All will be needed. In any field, those who know how to apply sources of talent once left untapped; who know how to recruit, how to train, re-train, and retain talent; how to educate, how to motivate, and promote -- those with that knowledge will prosper. This broader agenda must be part of a more comprehensive effort of affirmative action. The interests of economics and justice are coinciding now like never before. The door is opening wider now than it has ever been -- and we can open it still wider. Now is the time to extend a hand to all that struggle on the to other side -- and devote our energies to a broader agenda of m this new of fuctom, empowerment, that all might join the rolling thunder of ma jority. Let us look past the superficial differences that divide us, to the shared principles and better natures we have within us DR that none among us will be homeless, that no lives will be hopeless, that no children will be left in loveless, lonely rooms or stand in crowded doorways on dangerous streets. Let us hear the call for justice, and lend a hand to one another -- that no American will want for the advantages unique to America. In this new age of freedom, let there be no minorities. Let us usher America to a new age of ma jority Thank you, and fod bless you. # # # harmony betwee He races. AFFIRM. ACT WF 2000 over the last two days I've heard from X and y. Got, as I imagined I would, sound advice and yes, just a little constructive criticism. pursue & prosecute that is why I've pledged to support, and will sign into law, a measure to gain all the information we can on crimes motivated by religious, racial, or ethnic animosity -- the Hate Crimes Bill. And it's why I'm Affirm reducetto any deeply This felt, Commission and it S and a responsibility this administration I take share very a seriously conviction to assure that equal opportunity has real meaning -- and that we as a nation lead by example. I take very seriously our responsibility affirmative action is no longer just a matter of social responsibility. It's not just a matter of legal compulsion. It's an (( idea whose time has come )). So today I'll be focusing on affirmative action in every sense of that phrase. Not merely through the traditional social perspective, though America is nothing if not compassionate. Not merely through the altruistic impulse, though The disabled, women, veterans, minorities, older workers -- all in growing demand like never before -- must be enabled and prepared for jobs now being created by technology and economic growth. Nobody talks much about it, but the interests of economics d justice are coinciding. The door is opening wider now than it has ever been. Now is the time to extend a hand to all still struggling on the other side, to help them through that door to an opportunity called tomorrow that waits more urgently than ever, on the other side. in demand. Needed. In the future, the market economy will make it a fact of life -- because the success or failure of American enterprise, like the American experiment itself, will depend on the quality of those engaged. Like any enterprise, those who know how apply sources of talent once left untapped; how to recruit, how to train, re- train, and retain talent; how to educate, motivate, and promote save Atevery stephe should be asking ourselves, what works. Because there's never "one answer" to the challenges we face in America. There are many creative solutions and we have to be willing to try them all. STRIKE Down AK BARRIERS DO ADVANCEMENT, Fore ALL PEOPLE That means new ideas, like school vouchers to give poor We are parents the power of an alternative, and choice in where to send commi Hedto their kids. More tenant control and ownership of public housing. new hand Tax credits for child care without restrictions of any kind, to give parents more flexibility and choice. hank people of choice that engroph in Here at home, we don't need more government. We don't need less government. We need capable government -- and a renewed sense that government exists to empower people. America's best A hope is the creative talent she's had all along -- through a revitalized democracy that applies the forces of the free market choice and decentralization -- emphasizing what works. We come from a tradition that seeks power to give it away to states, localities private enterprise, community groups, citizens of every kind It's a tradition that goes back 200 years A legacy our founding fathers left us that the world has re-learned only recently Democracy. is another way of saying opportunity. property contributed to No BARRIERS to NO INSIDE PACKS, THO-TIERED M.S., injustices ave by MAY a NO onts CEILING together, No TOKENISM, FAVORI RSM BIAS SENISAX RUNGLESS LADDERS in a Guide to the Perplered SAVE l Rold w/ A Ahlosopher of the 12th C, who said Anticipate clarity by Mich preving perrly pinople Mitchell allow -- those with that knowledge will prevail. And that broad agenda -- the agenda of empowerment -- must be part of a more comprehensive goal for affirmative action. For the legal profession -- for so long, so effective at squeezing justice out of the clash of opposing views --- I think some of the best new opportunities will lie in crafting ways to facilitate cooperation. dive offered hand Aromiser Demindyou today: we oppose discrimination and bias of every kind, in any form, against anyone. There's a natural tradition that distrusts bureaucracy. Just compare the time you spend in your local fastfood restaurant to the time you spend in your nearby government agency, and you'll know what I'm talking about In the 1980's we faced extremes of greed on Wall Street and the homeless on mainstreet. And we struggled to overcome obstacles less tangible but no less troubling than the Berlin Wall: false divisions and barriers between left and right have's and have nots, black and white. now, for I want Americans to think about the goals and values they share -- not the differences that divide them. The commonwealth and well-being of our nation demand that we find strength in shared principles. Because behind the false barriers, beyond the heat of politics, we all want the same things: A just society. Opportunity. Prosperity. with hope, that the 1990's might be a thoughtful decade, more committed to community. It is time to reaffirm the values we share. Like many before, I sought the Presidency for a single purpose -- and believe that government has a singular responsibility -- to use power to help people. America transcends adversity, and finds her highest expression and greatest power, in diversity. Ours is a nation of imagination. Of principle, and SAVE tolerance. Of quiet strength. Faith. And freedom. So the government of such a nation should be active -- but ! not invasive. Democratic -- but not bureaucratic. And it should show restraint and a healthy humility -- for if the crumbling of centralized bureaucracies and the collapse of dictators has reminded us of anything, it is this: The center of power is not an entrenched bureaucratic elite -- it is the people. And the best government does not rule -- it serves. '90-05-01 12:23 DOUG GAMBLE P.2 2 DOUG GAMBLE TO: STEPHANIE LAUDNER - GOP DALLAS (CONT'D) THERE'S A COUNTRY & WESTERN SONG CALLED "MOMMA, DON'T LET YOUR BABIES GROW UP TO BE COWBOYS." WHAT IT DOESN'T TELL YOU IS THAT A COWBOY CAN GROW UP TO BE GOVERNOR OF TEXAS. I'M AFRAID THE DEMOCRATS AREN'T GOING TO LIKE WHAT CLAYTON WILL DO TO THE TRUTH IN THIS CAMPAIGN. HE'S GOING TO TELL IT. I HAVE A MESSAGE FOR ANYONE OUT THERE WHO THINKS THE NEXT GOVERNOR X OF THIS STATE WILL BE A WHITE-HATRED GRANDMOTHER WITH A FE-ISTY PERSONALITY AND A GOOD SENSE OF HUMOR: BARBARA BUSH HAS NO INTEREST IN ELECTIVE OFFICE. IF THE DEMOCRATS WIN THIS ELECTION. IT WILL BE "OK" TO HIGHER TAXES AND "OK" TO MORE GOVERNMENT SRENDING. THE LAST THING TEXAS NEEDS IS TO HAVE THE GOVERNOR'S OFFICE TURNED INTO THE "OK CORRAL." see Hoops on G.B. John Jacks Whateverg young Boy drown Bush bas to support afferia. action Ring define it: and full eg. undr law 200tas cloud the issue. astigna > ~ A blird society is not one flirt fogustice Magorty of fach And are Sport to garotar there is no digiting in injustive. oplandiess Nilam don't discredit the ashievements of black Ami. end discrim fall kinds no asterishs not by inducing it against afew We should rotdinde by group -- class division. do it by numbers Confonering be all Ave, not impoverishing Haiting / not dividing in a paint by #3 game statistice are not the arbiters of girstice Walabe sure that roble intertis don't Paye united 3144 CONGRESSIONAL RECORD - SENATE March 26, 1990 looking at a trade deficit on oil alone But we know otherwise. Rather than Mr. HATCH. I am glad to have been of $100 billion. be crushed, we know that the courage present to hear his remarks today Mr. President, the Senator from of Gustavo and Sebastian will one day Mr. GRAHAM. I express my appre- Alaska intends, over an extended crush Castro and his dictatorial ciation to the Senator from Utah. I period of time, to speak on this danger regime. know of his deep interest in human that is moving at 8 very rapid rate. I I ask unanimous consent that a copy rights and especially issues affecting will be proposing some alternatives to of a letter I intend to send to U.N. Sec- the civil rights and human rights of initiate exploration domestically so retary General Perez de Cuellar be the citizens of Cuba that we may have some independence, printed in the RECORD. Mr. HATCH I thank the distin- because as sure as I am standing here, There being no objection, the letter guished Senator from Florida. I wish one of these days in the not too dis- was ordered to be printed in the to associate myself with his remarks I tant future we are again going to be RECORD, as follows: think Castro has done some awful held hostage by the Mideast, and the U.S. SENATE, things ever since he has been there public will come to the Halls of Con- Washington, DC, March 26, 1990. and a lot of commentators in this gress and blame those of us who have Hon JAVIER PEREZ DE CUELLAR, Secretary General, the United Nations country have allowed him to do so. not seen fit to make adequate allow- New York, NY. That happened right up until the time ances for the inevitable Mr. President, DEAR MR. SECRETARY GENERAL: Fidel Armando Valladares wrote his book the handwriting is, indeed, on the Castro within the last two weeks has re Against All Hope." Having served wall. newed his harsh crackdown on human more than 20 years in Castro prisons I thank the Chair I yield the floor rights activists in Cuba, many of whom co-1 and describing the hideous conditions The PRESIDING OFFICER (Mr. operated with the United Nations in its that exist there, I think we are all in- first-ever investigation of Cuban human BRYAN). The Senator from Florida rights in 1988. debted to people like Armando Valla- [Mr: GRAHAM] is recognized We are writing to request that you move dares. I think we are indebted to the Mr. GRAHAM. I thank the Chair. quickly on the latest resolution approved by distinguished Senator from Florida for the U.N. Human Rights Commission on the work he is doing in this area. March 6 calling on the Government of Cuba HUMAN RIGHTS ABUSES IN to honor Its repeated guarantees not to sub- CUBA ject these individuals to "reprisals, deten- CIVIL RIGHTS ACT OF 1990 tion, or negative consequences of any nature Mr. GRAHAM. Mr. President, whatsoever.' Mr. HATCH. Mr. President, I believe within the last several weeks, Castro In the latest crackdown, Castro rounded the Civil Rights Act of 1990 is funda- has begun a new and harsh crackdown up 11 activists in early morning raids on mentally flawed. We have held four on human rights advocates in Cuba. March 12. Mobs of youths also surrounded hearings, Mr. President, in the Labor He has thrown 11 dissidents into jail, the houses of two of the most prominent Committee on S. 2104; the so-called and he has set loose his thugs to human rights leaders in Cuba, Sebastian Civil Rights Act of 1990. The hearings and Gustavo Arcos: harass and intimidate others All be- The latest arrests brings to 31 the number have made it very, very clear that this cause some of them had the temerity of people who have detained without trial bill goes far beyond merely overturn- to, send a letter congratulating the or been charged with political crimes since ing a few Supreme Court decisions U.S. delegation to the United Nations U.N: investigators visited Cuba in Septem- from 1989. It overturns numérous deci- Human Rights Commission. The Com ber 1988. sions; both the Supreme Court and mission on March 6. approved a United The recently approved resolution also lower court deicisons, some stretching States-sponsored resolution criticizing called on you to provide the texts and re- back to the 1970's And its proponents Cuba's human rights record and call- sults of the oral and written contacts you do not even claim that it is aimed at have maintained with the Castro govern- ing for a reexamination next year At ment on this question. We would appreciate merely :overturning the Supreme a time when Nelson Mandela has been meeting with you to discuss your findings. Court decisions from last year, in any set free in South Africa and when In the meantime, we urge the U.N. to do event playwright Vaclav Havel is leading everything in its power to gain the release As the Daily Labor Reporter, a non- Czechoslovakia toward democracy. of those who took such grave risks to ad- partisan newsletter, aptly said in its Castro remains a political dinosaur. vance the cause of human rights. February 9, 1990, issue, the bill "goes People around the world are demand- Sincerely, far beyond addressing recent Supreme ing democracy. Their leaders are lis- Mr. GRAHAM. Mr. President, I wel- Court rulings and amounts to a virtua tening and responding. But not Castro. come cosigners, I call on the Secretary wish list for plaintiffs in employmen He refuses to. He called the latest U.N. General to act on most recently ap- discrimination litigation." resolution disgusting. proved U.N. resolution calling on The bill will work fundamenta What is disgusting is that Castro Castro to respect human rights. Many shifts in title VII of the 1964 Civ: continues to abuse and intimidate the of those arrested in the recent crack- Rights Act. it will transform title VI citizens of Cuba. down cooperated with the United Na- from a statute aimed at conciliation One of those citizens is Sebastian tions. in its first-ever investigation of administrative resolution, settlement Arcos, a human rights leader who once Cuban human rights in 1988. Despite and placing a victim of discriminatio fought alongside of Castro but was guarantees to the contrary, Castro has in his or her rightful place in the wor later imprisoned for :counterrevolu- been harassing these individuals ever force into a statute in which conflic tionary activities In other words, he since. in the workplace will be exacerbate opposed Castro and communism. For The United Nations has a special ob- Protracted: costly litigation will be th that, he and his brother Gustavo, who ligation to those who took grave risks weapon of first. resort. The bill wi also fought at Castro's side in the rev- and paid a steep price to bring before simply be a bonanza for lawyers. olution, have been subjected to endless the world Castro's systematic abuses Further, the bill. will convert tit harassment by the Castro government. of human rights. These individuals de- VII from a statute guaranteeing equ: As part of the latest crackdown, serve. the United Nation's continuing opportunity for individuals, into thugs recently surrounded Gustavo's involvement, commitment and protec- statute virtually compelling quo: home in Havana, presumably because tion. The Secretary General should hiring by all public and private er human rights leaders were meeting to act immediately to gain their release. ployers of 15 or more persons. Eve form a united front. The PRESIDING OFFICER. The the Washington Post acknowledge They painted Gustavo's house with Senator from Utah [Mr. HATCH] is rec- this concern in a March 16, 1990, ec slogans like "Death to the Worms" ognized. torial wherein the Post said: and "Socialism or Death." Castro calls Mr. HATCH. Mr. President, I ask That issue-quotas-should be taken se Gustavo and Sebastian cockroaches the Senator to put me on as a cospon- ously. It is not just the false fear or red h- and VOWS that the people will crush sor. I will be glad to sign that letter ring that civil rights groups too readily C them Mr. GRAHAM. I appreciate it. miss It as being. March 26, 1990 CONGRESSIONAL RECORD SENATE 3145 In addition, this bill will severely re- Over the past 25 years, a rich and broad strict access to court for ¿certain per- mosaic of federal civil rights laws, ranging practices, a great victory for civil rights sons seeking to assert their most fun- from employment, public accommodations, plaintiffs. She then went on to say, basical- federally aided programs, to housing, insti- ly. everything I said in my opening state- damental right to equal protection of ment: the laws and the right to be free of tutionalized persons, and more, have been put in place. I have no doubt that more We agree that the inevitable focus on the invidious discrimination in viola- needs to be done to combat the evil of dis- statistics in disparate impact cases could put tion of Federal statutes. It will deny crimination in our society and hope that we undue pressure on employers to adopt inap- certain persons the opportunity for a can work together to achieve this important propriate prohphylactic measures. It is com- full trial on the merits of such a claim goal. pletely unrealistic to assume that unlawful with the full right of discovery and The Civil Rights Act of 1990 is designed to discrimination is the sole cause of people the right to appeal. overturn several recent Supreme Court failing to gravitate to jobs and employers in That is abominable. People have to cases. In fact, it overhauls two federal stat- accord with the laws of chance. It would be start reading this bill and look at what utes, throws out years of Supreme Court equally unrealistic to suppose that employ- and appellate court decisions, and conflicts ers can eliminate; or discover and explain, it does. directly with several core concepts of Ameri- the myriad of innocent causes that may lead I want to quote a few sentences of can justice. to statistical imbalances in the composition the testimony of James Henson, a Bir- Some areas of the legislation have merit. of their work forces. Congress has specifical- mingham, AL, firefighter. Mr. Henson For example: I have concluded that Section ly provided that employers are not required 1981 should be amended to ban racial dis- to avoid "disparate impact' as such;" citing a ranked sixth on a promotion list, but crimination in the terms and conditions of specific provision of Title VII (Section was passed over because of his race in 703(j)) favor of someone ranked 85th, in order contracts, as well in their formation and en- Preferential treatment and the forcement. Thus, the Patterson case, in my use of quotas by public employers subject to to implement a consent decree in a view, should be overturned. Moreoever, I be- Title VII can violate the Constitution, and it case to which Mr. Henson had not lieve that Title VII should be amended so has long been recognized that legal rules been a party. In addition, Mr. Henson that persons can challenge allegedly dis- leaving any class of employers with 'little had done a number of things to edu- criminatory seniority systems at the time a choice' but to adopt such measures would be cate and train himself and to get ad- person is aggrieved by such 8 system. Thus, 'far from the intent of Title VII,' quoting vanced understanding and experience the Lorance decision should, in my view, be Justice Blackmun. Albemarle Paper Co., 422 that the other candidate had not done. overturned. I have introduced legislation, U.S., at 449, 95 S.Ct., at 2390 (Blackmun, J., prepared and supported by the Admininis- concurring in judgment). Mr. Henson said: tration, which achieves these salutary objec- Thus, Justice O'Connor acknowledged I am a working class man. I am not re- tives. that: "extending disparate impact analysis sponsible for any past discrimination by the On the other hand, Mr. Chairman, I don't to subjective employment practices has the city of Birmingham. I did not cause any dis- believe we have to overhaul the American potential to create a Hobson's choice for crimination and should not have to pay the legal system to ensure equality. We don't employers and thus to lead in practice to price for it. The city of Birmingham should have to award some groups more legal perverse results. If quotas and preferential pay the price for its own wrongs. I am not a rights than others to guarantee the civil treatment become the only cost-effective lawyer, but I think I can tell when I have rights of all Americans. We don't have to means of avoiding expensive litigation and been treated unfairly. make quotas the only legal employment potentially catastrophic liability, such meas- policy in order to provide equal opportunity. ures will be widely adopted. The prudent Mr. Chairman, all I am seeking is a day in employer will be careful to ensure that its court to show I am a victim of unlawful dis- The major problem ares in the bill are as crimination. I filed suit promptly after I was follows: programs are discussed in euphemistic denied a promotion [on the basis of my 1. This bill is a litigation bonanza for law- terms, but will be equally careful to ensure that the quotas are met. Allowing the evolu- race] I am pleased that the Supreme yers. tion of disparate impact analysis to lead to Court has ruled that I am entitled to a day 2. Sections III and IV so dramatically this result would be contrary to Congress' in court. I urge this committee not to take change Title VII that the only way to avoid being sued is to hire solely by numbers, to clearly expressed intent"-at least until Ieg- away my opportunity to show that I have islation like S. 2104 becomes law, if it ever been discriminated against. use quotas for hiring and promotion. does it should not be the effect of our Mr. Henson happened to be a white 3. Under Sections III and IV of this bill, decision today. hiring the most qualified applicant may no firefighter. He was denied this promo- We. recognize, however, that today's longer be an acceptable defense to a charge tion solely because he was white. And of discrimination. extension of [the disparate impact] theory the promotion went to a man who was into the context of subjective selection prac- 4. Sections III and IV of the bill conflict tices could increase the risk that employers 79 positions below him on the list for with the fundamental principle that one is will be given incentives to adopt quotas or to this job. He was sixth. The other man innocent until proven guilty. The bill for engage in preferential treatment. Because was 85th. Though black; that was the the first time will shift the burden of proof sole reason why he was chosen over from the plaintiff to the defendant in dis- Congress has so clearly and emphatically expressed its intent that Title VII not lead parate impact cases. Mr. Henson. 5. Section VI conflicts with the fundamen- to this result, 42 U.S.C. Section 2000e-2(j), Mr. President, had Mr. Henson par- we think it imperative to explain in some tal principle that every American should ticipated in discrimination, I would detail why the evidentiary standards that have the same right to his or her day in apply in these cases should serve as ade- have no sympathy for him. But he ab- court. quate safeguards against the danger that solutely had nothing to do with it, and 6. This bill would even overturn a Justice Congress recognized." his testimony showed that: Nobody Brennan decision as to what constitutes in- And then Justice O'Connor, in her four can deny it. tentional discrimination. member plurality opinion, laid out the Mr. President, I ask unanimous con- Mr. Chairman, I want to compliment you standards for proving a disparate impact for holding four days of hearings on this sent that Mr. Henson's testimony and case. These are the very same standards bill. I look forward to working with you on the testimony of some of the other adopted by a majority of the Court, with the other days of hearings to ensure that we witnesses, along with my opening the addition of Justice Kennedy, in Wards have the benefit of all available expertise. S. Cove. statements at the hearings be printed 2104 is an extremely complicated bill that In Wards Cove, the Court held: in the RECORD at this point. will affect millions of Americans. We must In order to use statistical evidence to es- There being no objection, the mate- not legislate by label but take all the steps tablish a prima facie of disparate impact, rial was ordered to be printed in the necessary to understand the legal ramifica- you must make a comparison between the RECORD, as follows: tions of what is being proposed. percentage of qualified minorities in the rel- OPENING STATEMENT ON S. 2104, THE CIVIL evant labor pool and the percentage of mi- ADDENDUM TO SENATOR HATCH'S OPENING RIGHTS AcT OF 1990, SENATOR ORRIN G. norities in the job in question. To compare STATEMENT the percentage of minorities in an employ- HATCH, FEBRUARY 23, 1990 In the Watson V. Fort Worth Bank and er's unskilled jobs to their percentage in Mr. Chairman, all of us agree that one of Trust case, decided in 1988, Justice O'Con- skilled jobs, is "nonsensical," as Justice the most important functions of govern- nor warned us about the real risk of impos- White said. ment is to guarantee equal opportunity ing quotas on the American people if the A plaintiff must then demonstrate that under the law. Discrimination on the basis Title VII disparate impact theory is mis- the disparity results form the employment of race, ethnicity; religion, handicap, and used. In that case, the Supreme Court actu- practice(s) he or she is challenging. not gender is immoral and contrary to the most ally extended the application of the dispar- merely assert that the employer's entire set fundamental ideals of our country ate impact theory to subjective employment of hiring practices results in an imbalance. 3146 CONGRESSIONAL RECORD SENATE March 26, 1990 This seems an-obvious requirement for a cannot support wholesale changes in our es- overturning the Wards Cove V1 Atonio deci- prima facie case. As Justice White said, "To sential civil rights laws when such changes, hold otherwise would result in employers sion, and "jimmying" the rules of proving a in effect; overturn many time-honored prin- case of disparate impact discrimination, S. being potentially liable for 'the myriad of ciples-principles which are dear to every 2104 would work a radical transformation of innocent causes that may lead statistical im- American. Title VII. It would convert Title VII from 8 balances in the composition of their work This legislation would shift the burden of statute focusing on equal opportunity for forces. proof to defendants- in disparate impact individuals to one presumptively requiring, Once the plaintiff makes a prima facie cases, meaning that one is guilty until indeed virtually compelling, quota-type case by showing a relevant disparity result- proven innocent. This legislation would se- hiring and promotion for groups. ing form the employer's practice(s), the em- verely limit the right of certain workers af- Under Sections 3 and 4 of S. 2104; all a ployer has the burden of producing evidence fected by a consent decree, to challenge that plaintiff needs to do to win a Title VII law- of a legitimate reason for the employment decree in court when they claim to be suit is to show that an employer has a practices in question. harmed by it. This would deny Americans racial, ethnic, or gender imbalance in a job- That is, the employer's burden is to their equal right to their day in court. By without identifying any particular employ- produce evidence that its challenged introducing punitive and compensatory ment practice as having caused the imbal- practice(s) serves in a significant way legiti- damages and jury trials to Title VII, the leg- ance. Period. For example, suppose that mate employment goals; the employer need islation provides a windfall for attorneys 20% percent of the accountants in a labor not produce evidence that the practice is and creates an incentive to engage in market are members of a particular racial or necessary or essential to effective job per- lengthy litigation rather than to settle dif- ethnic group. Suppose further that only formance. The latter is an impossible ferences. I submit to my colleagues here in 10% percent of the accountants in an ac- burden for employers to meet. It would the Senate that this incentive moves our counting firm in that labor market are from cause an erosion of standards and force em- nation no further toward the kind of society that group: That business is going to be ployers to adopt quotas in order to avoid li- we seek-one in which irrelevant factors found guilty of racial discrimination unless ability. such as race play no role in employment de- the business can not only prove its inno- The burden of persuasion in these cases cisions. cence, but do so under a virtually impossible remains with the plaintiff-an elementary Some of the aspects of this bill which will standard. An employer could only avoid li- part of how our civil justice system works. be covered today are of particular interest. ability if he meets a burden of persuasion The plaintiff under Title VII must prove With the exception of the Patterson case, that all of his job criteria either did not con- discrimination has occurred, the defendant which we both agree warrants redress. the tribute to the imbalance or are essential to is not required to prove his innocence, i.e. significant changes contained in Sections 5 effective job performance. This burden that he has not discriminated. Thus, once and 8 of this bill do not even purport to be a would be virtually impossible to meet, and the employer produces evidence of the legit- "restoration" of the law to where It was one which finds no precedent in Supreme imacy of the practice in question. the plain- before the Supreme Court's 1989 term. Court decisions. tiff must show that the proffered business They clearly represent a substantial depar- In order to avoid liability under this ex- justification is a pretext or otherwise not le- ture from the Civil Rights Act of 1964. traordinary burden, employers would have gitimate. This is how the federal rules of Section 5 of this bill would overrule Price to hire and promote on a quota basis to evidence operate. Federal Rule of Evidence Waterhouse D. Hopkins, a plurality decision avoid these disparate impact lawsuits-to 301. written by Justice Brennan which was a vic- avoid, in short, what Justice O'Connor Even then, if the plaintiff cannot prevail tory for civil rights plaintiffs. This section called "expensive litigation and potentially on the business justification question, he or goes further than that opinion by reversing catastrophic liability." This precise concern she may still prevail by coming forward the general rule that, in employment cases, was expressed by Justices White, O'Connor, with alternative employment criteria that a plaintiff must show that the defendant's and others in several cases, including Wards reduce the disparate impact of existing em- unlawful conduct caused the injury. The Cove V. Atonio and Watson V. Forth Worth ployment practices. But these alternatives change here is significant. This bill would Bank and Trust. must be equally effective in serving the em- allow punitive and compensatory damages In short, rather than requiring nondis- ployer's legitimate employment goals. and attorneys fees even in cases where an crimination and equal opportunity, Title There is nothing unusual about this. It employer has proven that it would have VII's touchstone would become proportional has all been said by the Court before. E.g. made the same decision for nondiscrimina- representation and equal results on the New York Transit Authority v. Beazer, 440 tory reasons. basis of race, ethnicity, and gender-in U.S. 568, 587 n.31 (1979); Albermarle Paper Section 8 of this bill proposes, though not other words, quotas, however surreptitious- Co. v. Moody, 422 U.S. 405. 413 and n.7,. 425 in response to any Supreme Court decision, ly adopted or euphemistically described. (1975); Griggs v. Duke Power Co., 401 U.S. to expand Title VII to make punitive and I believe the Administration is dedicated 424, 431, 432 (1971); See also Watson v. Ft. compensatory damages, including damages to preventing this terrible result, and I join Worth Bank and Trust, 108 S.Ct. 2777, 2787- for pain and suffering, available in disparate them in that resolve. Attorney General 2791 (1988); NAACP v. Medical Center, 657 treatment cases. Thornburgh said on February 7, 1990: "The F.2d 1322, 1334-1336 (3rd Cir. 1981). I am concerned that this would change Administration's firm commitment to elimi- These standards reflect prior Supreme Title VII from a statutory scheme aimed at nate employment discrimination also means Court precedent in each particular, includ- conciliation and the administrative resolu- that we continue to oppose racial quotas. ing Griggs, not a departure from precedent. tion of allegations into one in which litiga- Discrimination is wrong no matter at whom They implement the disparate impact tion is the first, not last, resort. To change it is directed. The Administration, there- standard in a sensible way, they do not over- the Act in a way that would discourage fore. opposes any legislation aimed at over- turn it. rather than encourage the prompt and equi- turning three Supreme Court deci- table resolution of employment disputes sions," including Wards Cove Packing Co. v. OPENING STATEMENT, SECOND HEARING ON could, in the long run. heighten rather than Atonio The Attorney General described this CIVIL RIGHTS Acr OF 1990, SENATOR ORRIN lessen racial and other conflicts in the work- decision and two others, including Martin V. G. HATCH, FEBRUARY 27, 1990 place. Indeed, one provision of the bill, sec- Wilks, as "decisions rooted in the Court's I join the Chairman of the Committee in tion 9, makes it illegal to condition settle- opposition to racial quotas, which we share. extending appreciation and welcome to our ments on the waiver of attorneys fees, thus We urged the Court to reach the decisions it witnesses this morning. We will be hearing overturning yet another Supreme Court de- did in each of these cases; we agree with from Mr. Donald Ayer. Deputy Attorney cision in Evans v. Jeff D. This will make it them. and will oppose any legislation that General of the United States, several even more difficult to settle cases; this will seeks to overturn them." former members of the Equal Employment delay, not foster, simple justice. As Stuart Taylor, Jr., observed in a recent Opportunity Commission, and others re- Mr. Chairman. I reiterate that we both issue of Legal Times: "Under [this] bill garding this legislation. seek equality of opportunity in the work- the beneficiaries of disparate-impact suits None of us will argue that discrimination place. Unfortunately, there are certain prin- would not necessarily be victims of discrimi- does not exist today. We have all seen its ciples of justice which would be turned on nation. And the defendants would not nec- ugly head. We need strong and effective im- their heads if this legislation were enacted essarily be guilty of anything but hiring and plementation of our civil rights laws. Where in its present form. I find it discouraging promoting the people they consider the best there is a need to improve civil rights en- that we are asked to overturn these funda- qualified." forcement, I will be a strong advocate for mental rights of citizens in order to prove No one should be fooled by irrelevant lan- such improvement. our support for equal opportunity. This is guage in the bill intended to camouflage its We agree, Mr. Chairman, that some strictly an unfair exchange for everyone. import. Sections three and four are the op- change in these laws is desirable. I have in- erative provisions of the bill. Those-sections troduced legislation prepared and supported OPENING STATEMENT OF SENATOR ORRIN G., overturn Wards Cove by stacking the rules by the Bush Administration to overturn the HATCH, MARCH 1, 1990 of proving a disparate impact against em- Supreme Court's decisions in the Patterson Thank you, Mr. Chairman. Today we con- ployers in the manner I mentioned earlier. and Lorance cases. But, Mr. Chairman, I sider the Wards Cove V. Atonio decision. By The concern in this bill is not about court- March 26, 1990 CONGRESSIONAL RECORD SENATE 3147 ordered remedies or conciliation agree- ments. It is the radical revision in the stand- decree or judgment. That is wrong Let those innocent nonparty employees have a the list. When the Chief interviewed me for ard of disparate impact liability and misuse of statistics that create the severe quota chance to bring their subsequent claim, too. a promotion he said that would not be pro- This transparent double standard is an moted because I am white. The Chief said threat of S. 2104. The bill's denial that it ad- unedifying example of the extent to which that he had no choice in the matter because dresses "affirmative action," which is not modern American liberalism has departed 50% of the promotions had been set aside defined in any event, is irrelevant. The oper- ative language of sections three and four from the principle of equal justice under for blacks under the Consent Decree the law. City had entered into 2 years earlier. create the problem I described. I might add that Wards Cove is fully con- Does Section 6, by overturning Martin V. Carl Cook, the black firefighter who got Wilks, seek greater finality in employment my promotion, as shown on this chart, was sistent with the Griggs V. Duke Power Com- ranked No. 85 while I was No. 6 on the the pany decision, and Griggs remains good law discrimination cases? Yes and no. The great- er finality is sought only against innocent list. Mr. Cook. had been with the Depart- today. Moreover, whether or not Griggs has third persons but not with respect to civil ment 9 years while I was only there 6, so he led employers in the past to use quotas is to- rights plaintiffs got more seniority points than I did. Mr. tally Irrelevant to this bill. This bill does not Charles Alan Wright, Arthur Miller, and Cook was not qualified as a medic, had no codify Griggs, it twists Griggs completely A. E. Cooper, in their noted work, Federal Fire Science degree, had never worked as out of shape. It is S. 2104, and how it dis- Practice and Procedure (1981), wrote: the leadworker or acting officer and had no torts Griggs, that is the source of my The initial presumption that nonparties prior firefighting experience. I had all of present concern. are not bound by a judgment has been these qualifications. Despite my better I look forward to hearing the witnesses today. stated in many cases. This presumption qualifications and starkly higher test scores, draws from the due process right to be the Fire Chief told me I would not be pro- heard It is conceivable that some day moted because I am not black. Moreover, STATEMENT OF SENATOR ORRIN G. HATCH, this basic postulate may be eroded by courts Mr. Cook was never identified as a victim of MARCH 7, 1990 that believe that one full and fair litigation past discrimination, but received preferen- Thank you, Mr. Chairman. One of the of an Issue is sufficient without regard to tial treatment solely due to his race. Finally, the identity of the parties. It is much better, several years later I received my promotion most cherished rights we enjoy as Ameri- cans is the right to our own day in court however, to resist any such erosion. Our to Lieutenant and thereafter I was promot- when we believe we have been actually deep-rooted historic tradition that everyone ed to Captain. During those years, my harmed. S. 2104 is a harsh, illiberal effort to should have his own day in court draws career was on hold and I lost pay and se- niority solely due to my race. Aside from strip effectively certain innocent Americans from clear experience with the general falli- these tangible losses, this has been a demor- of their opportunity to assert equal protec- bility of litigation and with the specific dis- tortions of judgments that arise from the alizing experience for me and my family. tion claims under the Constitution, and em- I am a working class man. I am not re- ployment discrimination claims under feder- very identity of the parties. al statutes, in their own lawsuits. This could I intend to resist any such erosion sponsible for any past discrimination by the There is some irony, Mr. Chairman, in City of Birmingham. I did not cause any dis- well be the first serious effort in recent years to restrict access to the courts for per- Section 6. Other parts of S. 2104 overturn crimination and should not have pay the price for it. The City of Birmingham should sons who wish to assert fundamental consti- the Lorance decision: Thus, the bill permits pay the price for its own wrongs. I am not a tutional claims to equal protection of the persons like the women in Lorance to sue an lawyer, but I think I can tell when I have laws and basic statutory rights to be free of employer at the time they are harmed in been treated unfairly. invidious discrimination. fact by a seniority provision adopted with a Mr. Chairman, all I am seeking is & day in We will hear a great deal of lawyer talk discriminatory intent. I agree with that, and Court to show I am a victim of unlawful dis- about due process and what the Constitu- the bill I have introduced, S. 2166, reverses crimination. I filed suit promptly after I was tion does and does not require. And that, of that decision. But lets let every American denied a promotion: I had no knowledge of course, is extremely important. But we must have his or her right to a day in court at the the details of the litigation which resulted also keep in mind the impact of what we do time the individual is actually harmed. in the consent decree. If I get the trial and on the lives of people asserting the most Finally, Mr. Chairman, S. 2104 is not appeal and the Courts find that the-City's fundamental rights of all in our society. An merely content effectively to slam the conduct was legal, I can accept that and individual who is not a party to an employ- courthouse door in the face of innocent know that in America everyone is entitled to ment discrimination case, and who has not third parties in the future. By applying Sec- a day in Court. What I cannot accept is been joined under the Federal Rules of Civil tion 6 retroactively, this bill would literally having the City's agreement shoved down Procedure, should not be bound by the throw current litigants asserting constitu- my throat with no opportunity to a full and result in that case. This is so, in my opinion, tional equal protections claims and discrimi- fair trial to show that this is wrong. even if that individual has less formal notice nation claims right out of court and into the Thank you. of a proposed order or consent decree, or street without opportunity for redress. And even of the underlying lawsuit prior to the I suppose we will do that in the name of STATEMENT OF RAYMOND P. FITZPATRICK, JR., proposal of an order or consent decree. civil rights. BEFORE THE SENATE LABOR AND HUMAN RE- Unless an individual is a party to a case or SOURCES COMMITTEE, MARCH 7, 1990 actually represented in the case, as in a STATEMENT OF JAMES W. HENSON BEFORE THE class action. he or she should have the right SENATE LABOR AND HUMAN RESOURCES Com- Mr. Chairman, I am Raymond Fitzpatrick MITTEE, MARCH 7, 1990 of Birmingham, Alabama. I represent the to make his or her own claims of racial or nonminority firefighters of the Birmingham gender discrimination and denial or equal Mr. Chairman, I am James Henson, an Fire & Rescue Service in Martin V. Wilks. protection of the laws in an independent employee of the Birmingham Fire & Rescue lawsuit. Such an individual should have the Thank you for the opportunity to appear service. I am a plaintiff in the case which before this Committee to comment on Sec- right to do so within the appropriate statute was called Martin V. Wilks in the Supreme tion 6 of S. 2104. of limitations from the time he or she Court of the United States. I believe racial Martin V. Wilks was a correct decision claims to be actually harmed. discrimination is wrong no matter who it is which Congress should leave undisturbed. Indeed, this bill allows for just such a sub- directed against. I sued the City of Birming- The Supreme Court reaffirmed the funda- sequent lawsuit for some persons, but not ham because I was denied a promotion on mental principle of due process that all others. Supporse the EEOC or Department the basis of my race. I am pleased that the Americans are entitled to a day in Court of Justice files a lawsuit against an employ- Supreme Court has ruled that I am entitled when they believe they have been wronged. er on behalf of employees or job applicants to a day in court. I urge this committee not I wish to make it clear that Martin V. Wilks who are women or members of a particular to take away my opportunity to show that I is a decision designed to further the due racial or ethnic minority group. The persons have been discriminated against. process guaranties embodied in the Consti- on whose behalf the government is suing I joined the Birmingham Fire Department tution, and any legislative action in this are not parties, but assume that they have in 1976. At that time, blacks had been in the the notice S. 2104 describes. If the employer area must meet due process scrutiny. Those department for several years. I am not re- who claim that the Supreme Court was settles the case by consent decree, or judg- sponsible for any wrongs that may have oc- merely interpreting the Rules of Civil Pro- ment is entered against the employer. S. curred before or since that time. 2104 preserves current case law which per- cedure are wrong. The Supreme Court I had previously been the chief of a small mits those women or minority employees to quoted Justice Brandeis when it held: "it is suburban fire department but wanted to bring a subsequent lawsuit against that very a principle of general application in anglo- join a large department where my opportu- American jurisprudence that one is not same employer seeking greater relief for nities would be greater. I worked hard and themselves. And I think that is fine. bound by a judgment in a litigation in earned a 2 year college degree in Fire Sci- S. 2104, however, effectively slams the which he is not designated as a party or to ence and became a qualified paramedic. courthouse door in the fact of innocent em- which he has not been made a party by In 1983, I spent months studying for the ployees, not parties to the case, if they are service of process.' promotional exam and out of over 100 later harmed by the very same consent The Court recognized that this fundamen- people that took the test, placed No. 6 on tal due process principle was incorporated 3148 CONGRESSIONAL RECORD - SENATE March 26, 1990 into the Rules of Civil Procedure by the per- cuit and the Supreme Court held that it missive language of Rule 24 governing inter- was wrong to bind my clients to a settle- I should note that even the kind of notice vention and the mandatory joinder provi- ment they had no part in making. The Su- which may meet due process requirements sions of Rule 24. It is a principle which, preme Court remanded the case for a trial in bankruptcy or probate proceedings may both as a matter of due process and funda- on the validity of the City's race-based af- not pass muster when fundamental personal mental fairness, Congress should not dis- firmative action plan. rights are at stake. In the bankruptcy and turb. Despite nine years of litigation, my clients probate proceedings rights to a res-personal The fairness of this principle is demon- have only now been afforded an opportuni- or real property-must be affixed. Title to strated by the facts of the Birmingham litl- ty to demonstrate that the City's quota plan property must be clear. In an employment gation where the nonminority firefighters is outside the limits of permissible affirma- discrimination case, the right to equal pro- filed both lawsuits challenging the quota tive action. I urge the Committee to leave tection of the laws and the right to be free plan and a motion to intervene in the con- that decision intact and wish to make the of Invidious discrimination are at stake. sent degree litigation. In 1975, the United following substantive comments regarding I wish to stress that even if mandatory States filed suit against the City of Birming- this bill. intervention might be someday found con- ham and the Personnel Board, a separate Section 6 has a number of problems which stitutional in employment discrimination agency which screens applicants for City 1 wish to outline for the Committee: cases, it would not be the fairest or most ef- jobs. The Personnel Board's entry-level 1. The provisions governing the hearing of ficient manner of adjudicating those rights Police Officer and Firefighter examinations objections in part (A) of section 6 are viola- for the reasons stated in Martin V. Wilks. were found to violate Title VII, but not the tive of due process. A Fairness Hearing does 3. While terminating the right of nonpar- Constitution, and the District Court ordered not provide adequate protection to nonpar- ties to seek court review of their claims a hiring quota. The City of Birmingham was ties. Nonparties lack the tools of discovery when harmed by the implementation of a not found guilty of any discrimination. to prepare for a hearing, have no subpoena decree, the bill makes it clear that the Nobody has ever challenged that entry level power or other rights of parties and, most standards of Intervention remain un- order. In 1979, the District Court held a important, have no right to appeal when changed. In other words, intervention appli- second trial on the legality of other tests the district court signs the consent decree. cations at the time of approval of a decree and screening devices used by the Personnel An objector is not a party and does not have will be met with claims of untimeliness and Board. There was no attack made on any the rights of a party. lack of standing. As demonstrated by the Fire Department promotional examination. 2. The notice provisions of parts B and C facts of the Birmingham case, by the time a The City faced 8 potential backpay claim of also do not meet due process requirements. consent decree is announced, intervention is $5 million. Rather than wait for ruling, in The Court has upheld the termination of no option at all. 1981, the City secretly negotiated a Consent nonparty claims only in very limited statu- 4. The inconsistency and unfairness of the Decree in which it agreed to 50% quotas for tory proceedings, such as bankruptcy or pro- bill is also demonstrated in part (2)(B) of promotions to Fire Lieutenant, quotas for bate proceedings, where there is a clear section 6. While nonparties, who are usually all other jobs with the City of Birmingham, framework of rules to require actual notice nonminorities, are precluded from ever and paid only $265,000 to the victims of past to affected individuals, with a full comple- having a meaningful day in Court, the bill discrimination. Mayor Arrington has de- ment of due process guaranties. There are expressly preserves the rights of the benefi- scribed this arrangement as the "best busi- no guidelines regarding notice in this bill ciaries of the decree, usually minorities or ness deal" the City had evern made.¹ Indeed which even attempt to meet due process women, to seek further or additional relief It was, for the City settled the case on the standards to ensure actual notice to affected in other proceedings against the employer backs of innocent nonparties who them- individuals. The language of the bill which that is a party ot the decree. selves were not guilty of committing any dis- cuts off claims without service of actual 5. This bill will not reduce litigation, crimination. notice on known interested parties is con- rather it will cause a proliferation of unnec- The Birmingham Firefighters Association trary to the Supreme Court's recent due essary motions to intevene by persons who appeared at the District Court's Fairness process decision of Tulsa Professional Col- Hearing to oppose the quotas and urge the lection Services V. Pope, 108 S. Ct. 134 Court to require participation by the non- (1988). whereabouts are known, the party seeking to bind minority employees in the settlement proc- another must mail or personally serve specific ess. In addition, before approval of the notice of the action. Mullane, 317-318. In re Birmingham Reverse Discrimination Em- decree,2 the Firefighters Association and In Mullane, the Court struck down a state statute ployment Litigation, 833 F.2 1492 (11th Cir. 1987). permitting notice by publication to known benefici- two of its members moved to intervene so Martin V. Wilks, 490 U.S. 104 L.Ed.2d 835, aries in B proceeding for judicial settlement of trust they could contest the legality of the pro- 109 S.Ct. 2180 (1989). accounts despite the fact that the trustee knew posed decree. At the urging of the Lawyers A fairness hearing does not provide nonparty their identities and addresses. It made no difference Committee and the City of Birmingham, objectors with an adequate opportunity to be that Mullane received actual notice of the proceed- the District Court refused to allow interven- heard. See. Comment. Collateral Attacks on Em- ing and represented the interests of known benefi- tion, claiming we were five years too late. ployment Discrimination consent decrees, 53 ChiL claries. The Court held. at a minimum, Individual Rev. 147. 181 n.139 (1986) (use of 2 Fairness Hear- The Firefighters appealed. Again, the City notice by mail was required to be given to known ing to dispose of nonminority claims is the most ex- interested parties. Mullane, 318-320. and Lawyers Committee opposed interven- treme view). The fairness hearing held in this case In Tulsa Professional Collection Services V. Pope. tion saying the firefighters were years too by the district court did not provide objecting par- 108 S.Ct. 1340 (1988), the Court again upheld the late. should have intervened when the suits ties with the benefits normally accorded to parties duty to give adequate notice by mail to known in were filed in 1975, and had no standing to in litigation. Thus, the objectors were not able to terested parties. The Tulsa Court struck down ar contest the quotas because there had been engage in discovery. could not call witnesses or Oklahoma statute permitting notice by publication no injury. In addition, the Lawyers Commit- offer evidence, and, most importantly. could not to known creditors In a state probate proceeding tee told the 11th Circuit that the Firefight- appeal from the proceedings of the district court. The Oklahoma statute permitted notice by publica Indeed, despite over nine years of continuous litiga- tion for 2 consecutive weeks in a local newspaper ers should not be allowed to intervene be- tion, no appellate court has ever addressed the va- The publication commenced after the state probat cause they were free to file separate litiga- lidity of Birmingham's plan. either on Its face or as court opened the estate upon request of the execu tion to challenge the City's actions. The It applies to the firefighters. tor or administrator of the estate. The Court foun Eleventh Circuit held that intervention was The fairness hearing process, whereby nonparties that when private parties trigger a state statute o not necessary because individual firefighters are given the opportunity to voice their concerns limitations through commencement of judicial prt who are denied promotion should file sepa- through objections. does not rise to the level of the ceedings there is sufficient state action to implicat rate suits after they are in fact denied a pro- full hearing necessary to terminate the substantive the Due Process Clause. In such circumstance rights of nonparties. Rather. a fairness hearing is "due process is directly implicated and actual notic motion. Following the 11th Circuit's deci- much like the predeprivation conference in Cleve- generally is required" 99 L.Ed.2d at 577. The part sion. my clients pursued their suits under land Bd of Education V. Loudermill, 470 U.S. 532 giving such actual notice bears the burden of "re Title VII and the Fourteenth Amendment. (1985) where the charged employee is given the sonably diligent efforts to uncover the Ident The District Court summarily deemed its right to appear before the decisionmaker to coax, ties Id. at 578. The Court held that if the 11 decree valid and bound the nonminority object and respond to the proposed deprivation. but terested nonparties "identity was known or 'reaso: firefighters to the terms of the Consent not call witnesses or cross-examine those of the em- ably ascertainable,' then termination of appellant Decree they had no part in making. The ployer. Indeed. Loudermill provided that after a claim without actual notice violated due process deprivation of the employee is entitled to a full Id. at 579. District Court required the employees to hearing. Employees who are denied a promotion on The notice must be sufficient to apprise nonps show that the City was not following the the basis of race are certainly entitled to no less. ties of the nature of the decree-approval procee decree. We again appealed and the 11th Cir- The firefighters' suits are akin to the full post dep- ings. the effect of failure to seek intervention. a: rivation hearing required by Loudermill. the time limit for motions to intervention. Col The practical effect of the doctrine of mandato- ment. Collateral Attacks on Employment Discrin 1985 trial. PX 403. ry intervention is that parties to a consent decree nation Consent Decree, 53 ChiLRev. 147. 160-1 2 Intervention was sought on August 4. 1981. The may obtain a consent judgment from a court and (1986). Adequate notice must apprise the potenti decree was entered on August 21. 1981. make that judgment binding against all third par- ly affected nonparty of the procedure for resolvi 3 Brief of John W. Martin. et al., Appellees at 10, ties. Mullane V. Central Hanover Bank & Trust Co., claims at & hearing so as to permit the objector No. 81-7761 (11th Cir. 1982). 339 U.S. 306. 317 (1950) requires that in such of cir- adequately prepare for the hearing. Memphis Lig 4 United States V. Jefferson County, 720 F.2d 1511 cumstances, interested parties are entitled to the Water and Cas Division V. Crash 436 U.S. 1. 13 (11th Cir. 1983). "best notice practicable." If a person's identity and (1978). March 26, 1990 CONGRESSIONAL RECORD SENATE S3149 might never have a stake in the litigation at The Supreme Court in Martin V. Wilks great cost to them. Under this bill. every recognized that the existing rules provide a not one that infringes on the rights of inno- cent third parties. time an employer is sued under Title VII, framework to allow parties to negotiate con- the employees of that employer, as well as If the Birmingham decree is valid and the sent decrees yet ensure finality: the prospective employees of that employer, city has acted lawfully, then the Courts will 1. The existing parties to litigation are in must Intervene to preserve their right to rule against my clients and we must accept the best position to determine who may be contest a decree which might possibly affect that ruling. If it is not, then my clients have potentially affected by the relief sought in their rights if they seek a promotion in the been done an injustice, are entitled to be the litigation Federal Rule of Civil Proce- future.' heard, and should receive fair compensation dure 19 places the burden on the existing and an end to wrongful conduct. parties and the court to join all interested This bill is not content with just prospec- The questionable standing of nonminority Indi- parties in litigation. tive application. Under its transition rules, viduals to participate and their uncertainty about 2. Large numbers of similarly situated per- it seeks to throw any employment discrimi- whether they need to bear the expenses of litigat- sons may be joined into the litigation nation case involving a prior decree out of ing mean that third parties will often discover that through the class action mechanisms of court on a retroactive basis. Given the ef- their rights have been compromised but that It is Rule 23. In such a case, the Court must forts the Birmingham Firefighters made to already too late to move to intervene. The propo- nents of the bill claim a collateral attack bar saves ensure that the proper notice is given to intervene before entry of the decree. this judicial resources and litigation costs. On the con- class members and that the Interests of would be extremely unfair. My opponents trary. such a rule will encourage protective and class members are fully and adequately rep- would succeed in immunizing their racial often unnecessary intervention applications which resented. Moreover, unlike objectors at a program from appellate scrutingy forever. will unduly expand the breadth of discrimination Fairness Hearing, a class which is approved This Committee should understand that litigation. In fact, under such a rule, every employ- by the Court has the right to appeal from in our multiethnic society, a decree which ee of every employer sued for race discrimination may be placed in the position of having to hire the entry of a decree which affects its gives preferential relief for one group may, counsel to intervene to protect his or her position rights. at the same time, impact adversely upon in the workforce. Such a burden has never been We believe that racial discrimination other minorities or females. While we be- placed on strangers to litigation. See, Chase Nation- should be identified and eliminated and the lieve this bill is primarily aimed at white al Bank V. Norwalk, 291 U.S. 431, 441 (19330 ("law victims should be given a full remedy, but males, it will also cut off the rights of His- does not impose the burden of voluntary Inter- panics, women and other minorities seeking vention"). See also, Cooper V. Federal Reserve Bank to make progress in the workplace. of Richmond, 467 U.S. 867 (1984) (individual unliti- "standing to seek appellate review of the consent The Supreme Court recognized that allow- gated claims of class members not precluded de- Judgments." Brief of John W. Martin. 23, United spite the fact that other class members intervened ing suits such as Mr. Henson's will not States V. Jefferson County, No. 81-7761 (11th Cir.). to assert individual claims). create chaos but preserve the fundamental 10 Consent decree parties have an adequate In order to have standing, a party must have a right of all of a day in court. While we be- remedy through joinder of nonparties under rule recognizable interest which is traceable to the de- fendant's allegedly unlawful conduct. Allen V. 19, F.R.Civ.P. Such a mechanism clearly provides lieve section 6 does not provide a constitu- Wright, 468 U.S. 737 (1984); Gladstone Realtors V. the nonparty with a full complement of due process tional framework for adjudication of the safeguards by notice, through a summons, a date rights of nonparties and the principle of Village of Bellwood, 441 U.S. 91 (1979). The rules of Article III standing apply to intervenors as well as certain after which default may be entered. the Marting V. Wilks is good public policy, the original parties to. the litigation. Diamond V. tools of discovery, the opportunity to be heard retroactive application of the act is shock- Charles, 476 U.S. 54 (1986). through & full evidentiary hearing, and, most im- ingly wrong and unfair The City of Birmingham has some 3,000 employ- portant, the right to appeal any adverse decision. Thank you. ees. Over 600 are Birmingham Fire & Rescue Serv- Just as the employer believes the nonparty should ice ("BFRS") employees. It is wholly unrealistic to perceive its interest and intervene, 80 too may the STATEMENT BEFORE THE SENATE COMMITTEE require each individual BFRS employee to take employer perceive the interest of the nonparty and join the nonparty at the appropriate time. The em- ON LABOR AND HUMAN RESOURCES, FOR THE notice in 1975 through newspaper stories of the ployer has sophisticated counsel with knowledge of U.S. CHAMBER OF COMMERCE BY JAMES C. pendency of litigation. to learn that the litigation involves rights to promotional positions rather the proposed consent decree and the skills to per- PARAS, Ese., MARCH 1, 1990 than hiring discrimination, to foresee that their ceive the potential interest of the nonparty while Good morning. My name is James C. employer will settle rather than litigate and that the nonparty has no counsel or intimate knowledge Paras. I am a Senior Partner in the San they will be the ones to bear the burden of that set- of the federal court proceedings. Had Birmingham Francisco law firm of Morrison & Foerster tlement through implementation of the quotas. wished to bind the Firefighters to its settlement, it could have joined them under Rule 19 or refrained and a member and past Chairman of the Such an individual's interest in the litigation would certainly be speculative at best. from opposing intervention. The fact that joinder U.S. Chamber of Commerce's Labor Rela- Similarly, in 1981, it was unreasonable to require will Involve some cost should be of no consequence. tions Committee. I am also a member of the hundreds of BFRS employees to seek to Intervene See, Laycock, Consent Decrees Without Consent: governing Council of the Labor and Employ- in order to protect their right to a promotion which The Rights of Nonconsenting Third Parties, 1987 ment Law Section of the American Bar As- they might decide to seek in the future and which Univ. of Chicago Legal Forum 103, 144-153. Given sociation. Accompanying me today is Nancy might be denied If they obtain B score high enough its opposition to intervention, the city should not Reed Fulco. Human Resources Attorney for to be certified. Moreover, only a small portion of now be allowed to complain. Each time a complex claim of discrimination is brought before the courts the Chamber. Thank you for affording the those passing the Fire Lieutenant's examination are evern certified. involving diverse and competing interests, there are Chamber this opportunity to discuss the The union also cannot act as the surrogate for significant costs in terms of the litigation expenses impact of the proposed civil rights legisla- the employees. It represents a broad spectrum of and liability exposure of the parties as well as the tion on the business community. employees, black and white, officers and privates, allocation of scarce judicial resources. If the City Since the passage of Title VII of the Civil those with seniority and those without, as well as desires to engage in a settlement the cost of which Rights Act of 1964, this country has made those who intend to seek promotion and those who some third party is likely to bear. it should pay the tremendous strides both in eradicating em- do not. See, Wygant, 476 U.S. 281 n.8. price of either joining those parties in the litigation ployment discrimination and in eliminating Given the speculative nature in 1975 of the Fire- or facing the claims of those third parties in the future. Shifting the entire cost of settlement to in- artificial barriers to employment while at fighters' interest in the consent decree litigation. it is certainly unreasonable to place the burden on nocent third parties should not be permitted. As the same time protecting an employer's the individual nonminority employees of the City, Mayor Arrington has testified. the consent decree right to make reasonable and nondiscrim- not to mention persons who are not yet City em- was "the best business deal [the City] had ever inatory employment decisions. However, ployees, to intervene in the litigation. See Safir V. struck." J.A. 528. Congress should not countenance proponents of S. 2104, the Civil Rights Act Dole, 718 F.2d 475 (D.C.Cir. 1983) (Scalia, J.) "business deals" at the expense of strangers to the of 1990, claim that the Supreme Court has (Safir's possible future reentry into the shipping litigation. recently made "an abrupt and unfortunate business deemed too speculative to confer stand- In ensuring the rights of the Firefighters to due- process, the Supreme Court found that the Fire- departure from its historic vigilance in pro- ing). Moreover. protective intervention adds to the high cost of litigation of the existing parties as well fighters' claims against their employer are due to tecting civil rights." 136 Cong. Rec. S 1018 as subjects the intervenor to the possible assess- be heard in the context of independent suits. Such (Feb. 7. 1990). Based upon this assumption. ment of attorney's fees if the defendant is ultimate- a rule is a reasonable procedural device which pre- S. 2104 is offered to overrule numerous Su- ly deemed liable. See Diamond V. Charles, 476 U.S. serves the due process rights of nonminorities to preme Court decisions handled down over 54, 70 (1986); Reeves V. Wilkes, 754 F.2d 965 (11th have their claims heard. Firefighters believe their the past decade. With few exceptions. pro- Cir. 1985). Such costs and risks are simply too high suits are the preferable means of resolving these poonents contend that the bill would merely to preserve the future rights of nonparties to object types of claims. in view of the ability of the court to a potentially illegal consent remedy. not only to consider the facial validity of a decree- restore prior law and, therefore, presumably Moreover, the claim that the firefighters should emboided plan. but also the conduct of the parties have little impact on employers who already have intervened in the decree case contradicts the in implementing the plan. See, e.g., Johnson V. have been striving to comply with existing position which the City took in the appeal from the Transportation Agency, 480 U.S. 107 S.Ct. 1442 employment discrimination laws. intervention proceedings that the Firefighters (1987) (goal should be flexible based on the avail- From the perspective of the business com- lacked & Htigable interest which would support ability of minorities in relevant labor pool at the munity. nothing could be further from the intervention. In 1983. the City told the Eleventh time of the preferential promotion rather than truth. S. 2104 represents a multifaceted re- Circuit that the appellants lacked standing. See fixed at the time the plan is adopted): Fullilove V. Klatznik, 448 U.S. 448. 480-481 (1980) (Court only vision and expansion of the employment dis- J.A. 549 ("with respect to the promotional goals the approved facial validity of set-aside statute and did crimination laws that have developed over Firefighters fail to show a sufficient direct and per- sonal injury to its members"). Similarly, the Law- not foreclose future challenges on & case-by-case the past 25 years. If enacted. it would dra- yers Committee claimed the appellants lacked basis). matically alter the balanced between the S 3150 CONGRESSIONAL RECORD SENATE March 26, 1990 goal of eliminating discrimination In society Title VII, as written, "expressly protects the ed, can now be examined under the adverse and the goal of preserving & vital and effi- employer's right to insist that any prospec- impact theory. cient business environment capable of com- tive applicant must meet the applicable Wards Cove Packing Ca V. Atonio, 109 S. peting in an increasingly global economy. job qualifications." 110 Cong. Rec. S 7247. In Ct. 2115 (1989), is the first Supreme. Court This is so because S. 2104 would substantial- a separate memorandum, these Senators ly increase the burdens and risk of liability further stated that There is no require- case to examine the adverse impact analysis for every employer in this country, includ- ment in Title VII that employers abandon following the expansion of that analysis in ing the most exemplary. bona fide qualification tests where, because Watson. In Wards Core, the Court summa- The most troubling aspects of the pro- of differences in background and education, rized the adverse impact analysis as follows: posed legislation include the bill's adoption members of some groups are able to per- First, the plaintiff must identify the specific of a virtually irrebuttable presumption in form better on these tests than members of employment practices that the plaintiff con- favor of a quota system; penalization even other groups. An employer may set his tends are discriminatory and establish that, of those employers who successfully prevent qualifications as high as he likes in fact, each challenged practice adversely Id, at impermissible factors from affecting the S 7213 (emphasis added). From these state- impacts members of a protected group. Id outcome of employment decisions; substan- ments, the Griggs court concluded that se- at, 2124-25. Second, in the event that the tial and often open-ended expansion of the lection criteria are permissible despite their plaintiff establishes that certain practices time for raising discrimination complaints adverse impact on protected groups if they have such an adverse impact, the employer by some employees, while ironically short- are "demonstrably 8 reasonable measure of must produce evidence that each of the ening the time for raising such complaints job performance. Griggs, 401 U.S. at 430 challenged practices "serves, in a significant by other similarly situated employees; injec- (emphasis added) way. the legitimate employment goals of the tion of unpredictable and perhaps uncon- As the Court's subsequent decision in employer. [Citations omitted.] The touch- trollable elements of damages in employ- Furnco Construction Corp. V. Waters, 438 stone of this inquiry is a reasoned review of ment discrimination cases; and reduction of U.S. (1978), reflects, sound jurispruden- the employer's justification for his use of incentives for. discrimination claimants to tial and societal reasons support Congress's the challenged practices. A mere insubstan- settle their cases and restore work relation- original intent not to interfere with an em- tial justification in this regard will not suf- ships. In the section-by-section analysis that ployer's right to rely upon legitimate job-re- fice Id. at 2125-26. Finally, once the follows, these problems with S. 2104 will be lated selection criteria. In Furnco, plaintiffs employer has introduced evidence of reason- addressed. challenged an employer's reliance upon per- able business justifications for the chal- sonal and outside recommendations con- lenged practices, the plaintiff must come I. ANALYSIS cerning applicants' job qualifications. The foward with evidence of alternative prac- A. Section 4: Adverse impact analysis Court of Appeals ruled in favor of the plain- tices that could equally serve the employer's One of the principal thrusts of S. 2104 is tiffs and ordered the employer to imple- legitimate interests with a lesser adverse to overturn the Supreme Court's decision in ment a new hiring process based upon an impact on protected employees. Id. at 2126- Wards Cove Packing Co. V. Atonio, 109 S. evaluation of written employment applica- 27. The burden for establishing that the em- Ct. 2115 (1989), and in the process substan- tions. In reversing this decision; the Su- ployer is relying upon non-job-related prac- tially to rewrite the adverse impact analysis preme Court noted "[t]he dangers of em- tices remains on the plaintiff. utilized by the Supreme Court for the past barking on 8 course such as that chartered The tripartite analysis followed in Wards two decades. Contrary to the impression cre- by the Court of Appeals here, where the Cove is entirely consistent with prior Su- ated by its title, Section 4 of the bill would court requires businesses to adopt what it preme Court precedent. With respect to the not "restore" any preexisting Supreme perceives to be the 'best' hiring proce- plaintiff's prima facie case, there is simply Court interpretation of Title VII. Instead, dures. Not only does the record not no dispute that plaintiffs have been re- this Section would legislatively overrule not reveal that the court's suggested hiring pro- quired to identify and establish the adverse only the Wards Cove decision but also a cedure would work satisfactorily, but also impact of specific employment practices in number of other Supreme Court decisions, there is nothing in the record to indicate each Supreme Court adverse impact case including the Court's seminal decision in that it would be any less 'haphazard, arbi- preceding Wards Cove Se, e.g., Griggs; 401 Griggs V. Duke Power Co., 401 U.S. 424 trary and subjective' than Furnco's U.S. 424 (high school diploma and aptitude (1971). By shifting the burden to the em- method. Courts are generally less com- test requirements); Albermarle Paper, 422 ployer to prove, in the absence of quotas, petent than employers to restructure busi- U.S. 405 (aptitude tests); Washington V. that it did not discriminate and that the fac- ness practices, and unless mandated to do so Davis, 426 U.S. 229 (1976), (written tests); tors utilized in its employment process were by. Congress they should riot attempt it." Id. Dolhard V. Rawlinson, 433 U.S. 321 (1977) not only reasonable but also indispensable, at 578: (height and weight requirements); New S. 2104 would leave employers with little 2. Section 4 of the Bill, Rather than York City Transit Authority V. Beazer, 440 choice but to adopt quota systems in order Wards Cove, Is Inconsistent with Prior Ad- U.S. 568 (1979 (drug use policy); Connecti- to protect themselves from substantial li- verse Impact Decisions of the Supreme cut V. Teal, 457 U.S. 140 (written test); ability. Court: Watson, 108 S. Ct. 2777 (subjective promo- 1. Title VII Currently Preserves an Em- Two principal theories of proof under tion evaluations). Similarly, in Teal, the Su- ployer's Right to Establish Selection Crite- Title VII are "disparate treatment" and "ad- preme Court rejected "bottom line" analysis ria with a Potentially Adverse Effect on verse impact." Under the disparate treat- and required adverse impact analysis to be Protected Groups Provided the Selection ment theory. an employer is liable if it in- applied separately to each aspect of anem- Criteria Are Job-Related: tentionally treated a member of a protected ployment process. Teal, 457 U.S. 440. At the outset it should be noted that Con- group less favorably than other persons be- With respect to a defendant's rebuttal ob- gress never intended Title VII to force em- cause of the former's protected status. ligation. the Supreme Court likewise has ployers to abandon reasonable predictors of Texas Department of Community Affairs V. consistently held that an employer must job success that have been adopted without Burdine, 450 U.S. 248 (1981); McDonnell show that its practices are, in fact, "job-re- the taint of discriminatory intent. Instead, Douglas Corp. V. Green, 411 U.S. 792 (1973). lated" or possess a "manifest relationship" as the Supreme. Court's development of the Under the adverse impact theory, an em- to the employment in question. Wards Cove, disparate. treatment and adverse impact ployer need not have possessed any discrimi- 109 S. Ct: at 2130 n.14 (Stevens, J. dissent- models of proof establishes, only practices natory intent. Instead, the employer is ing) (quoting Teal, Beazer, Dothard, Alber- that are intentionally discriminatory or that liable if It utilized "artificial, arbitrary, and marle Paper, and Griggs.) This is true even create obstacles, to equal employment that unnecessary barriers to employment" that in cases such as Griggs, which used the al- are not reasonably related to job perform- had a disproportionately adverse impact terative formulation "business necessity." ance are prohibited by Title VII. upon members of a protected group. Griggs, In elaborating upon the meaning of busi- In Griggs itself, a unanimous Supreme 401 U.S. at. 431. In the words of the Griggs, ness necessity in Griggs, the Court immedi- Court observed that there had been sub- court, such unreasonable employment cri- ately explained that "If an employment stantial concern prior to the adoption of teria could not be allowed to become the practice which operates to exclude [a Title VII regarding whether the new law "masters of reality." Id. at 433. member of a protected group] cannot be could be construed to require employers to Prior to 1988, each Supreme Court case shown to be related to job performance, the select employees based upon their protected adverse impact decision had involved practice is prohibited." Griggs, 401 at 31. status, rather than their employment quali- 'standardized employment tests or criteria." Nowhere in Griggs did the Supreme Court fications. To allay this fear, "Proponents of Watson V. Fort Worth Bank and Trust, 108 say that a challenged practice had to be es- Title VII sought throughout the debate to S. Ct. 2777. 2785 (1988). In Watson, the Su- sential, indispensable, or otherwise absolute- assure the critics that the Act would have preme Court broadly expanded the scope of ly required in order for a business to func- no effect. on job-related tests." Griggs, 401 adverse impact analysis to encompass not tion. U.S. at 434 (emphasis added). Consistent only standardized or objective employment An issue not expressly resolved in Griggs with Congressional intent, Senator Case of factors but also nonstandardized or subjec- and subsequent Supreme Court decisions is New Jersey and Senator Clark of Pennsylva- tive factors as well. This means that very the precise degree of proof required by a de- nia, comanagers of the Senate bill, issued an aspect of the employment decision making fendant at the rebuttal stage. Although the influenial memorandum explaining that process, whether articulated or unarticulat- Supreme Court had used words such as March 26, 1990 CONGRESSIONAL RECORD SENATE 3151 "demonstrating," "proving," or "showing" to describe, the defendant's rebuttal obliga- obligation on a plaintiff A plaintiff's only obligation under Wards Cove and its prede- tions concerning the likelihood of establish- tion, it had never discussed whether this cessors was to meet the specific job-related- ing a business necessity defense. According- was a burden of production or persuasion. ness Justifications proffered by the defend- ly, the most reasonable alternative for many In Wards Cove, the Supreme Court conclud- ant in Its rebuttal. This is consistent with businesses would be the adoption of quotas. ed that the defendant carried a burden of the purposes underlying both. disparate Even this, of course, would not provide abso- producing evidence of its "job-relatedness" defense, but that the plaintiff retained the treatment and adverse impact analysis, dute protection, because employees harmed which is the orderly and focused presenta- by the quotas may also be able to prevail in burden of proving that the defendant had, tion of evidence. Cf. U.S. Postal Service a reverse discrimination lawsuit. Thus, Sec- in fact, relied on arbitrary or unréasonable Board of Governors V. Aikens, 460 U.S. 711 tion 4 truly represents a "no win" proposi- practices that adversely affected a protected (1983) (disparate treatment model "is tion for employers. group. This is entirely consistent with the merely a sensible, orderly way to evaluate B. Section 5: Mixed motivation Court's resolution of the same issue in the the evidence in light of common experience context of disparate treatment analysis. as it bears on the critical question of dis- Section 5 of the bill nominally is offered Burdine, 450 U.S: 248. Moreover, it would crimination"). Id. at 715 (quoting Furnco, to overturn the Supreme Court's decision in 'seem anomalous to impose a higher burden 438 U.S. at 577). In contrast, under Section Price Waterhouse V. Hopkins, 109 S. Ct. 1775 of proof upon defendants in cases involving 4, a defendant could no longer satisfy its re- (1989). In Price Waterhouse, the Supreme alleged intentional discrimination. buttal obligation by establishing that the Court addressed the standards applicable to Finally. if a defendant has identified le- practices in question are, in fact, reasonably "mixed motive" cases, i.e., cases in which gitimate job-related reasons for its employ- related to legitimate job expectations. In- legal and illegal factors allegedly entered ment practices, it has always been the plain- stead, the defendant will carry the much Into an employment decision. The plaintiff tiff's burden to identify and establish that higher, and in many cases impossible, had asserted that proof of an impermissible alternative practices could equally serve the burden of having to establish that no con- factor playing any part in the employment defendant's interests with 8 lesser Impact ceivable alternative practices could be process resulted in a finding of liability upon protected groups. See. e.g, McDonneu adopted that would be equally effective in against the employer, regardless of whether Douglas, 411 U.S. at 801; Albermarle Paper, accomplishing the defendant's business the impermissible factor affected the out- 422 U.S. at 425. goals. come of the employment decision in ques- Section 4, in combination with the defini- 3. Section 4 Will Inevitably Lead to the tion. The defendant, on the other hand, tions found in Section 3 of the bill, would Adoption of Quotas by Employers: claimed that the plaintiff must prove that şubstantially alter the adverse impact anal- There is no question that Title VII, as cur- the impermissible factor actually altered ysis developed by the Supreme Court since rently written, does not require employers that decision. the early 1970s in several major respects. to adopt quota systems. Indeed, Section The court selected a middle ground be- First, it would relieve the plaintiff of the 703(j) of Title VII expressly states that em- tween the positions advocated by either requirement of challenging specific employ- ployers are not required and logically party. First, the Court held that a plaintiff ment practices. Instead, it would permit the cannot be penalized for failing to adopt establishes a prima facie case by showing plaintiff to rely exclusively on "bottom line" quotas or preferences of members of pro- that an impermissible factor entered into statistics indicating an overall imbalance in tected groups. This has led the Supreme the decision making process. Id. at 1785-86. the work force. In the absence of any fur- Court to avoid the adoption of legal rules Thereafter, a defendant can avoid liability ther evidence, the plaintiff may prevail "leaving any class of employers with 'little only by proving that the impermissible based upon such bottom line statistics choice but to adopt such measures." factor did not alter the ultimate decision. alone. This conflicts not only with the Su- Watson, 108 S. Ct. at 2788 (quoting Alber- This requires the defendant to prove by a preme Court's Teal decision but also with marle Paper, 422 U.S. at 449 (Blackmun, J. preponderance of evidence that legitimate, Section 703(j) of Title VII, which expressly concurring)). nondiscriminatory reasons would have led states that employers are not required to Consistent with past Congressional intent, to the same result in the absence of the pro- maintain numerical balances or grant pref- the sponsors of S. 2104 belie any interest in hibited factor. Id. at 1786-88. erential treatment to eliminate numerical imposing quota systems through the lan- Justice O'Connors concurring opinion ex- imbalances. guage of Section 4. This denial, however, is plored more fully an issue left unanswered Second, Section 4 would raise the stand- unconvincing. by Justice Brennan's plurality decision. This ard of justification for challenged business When the Watson Court expanded ad- issue involved the importance that imper- practices from its current "reasonable meas- verse impact analysis to every aspect of em- missible factors must have played in the de- ure of job performance" standard to one re- ployment, not just discrete and objective se- cision process. Id. at 1790-91 and n.13. Jus- quiring evidence that the practices are not lection criteria, it expressed an obvious and tice O'Connor concluded that a plaintiff, at only reasonable but also "essential to effec- common sense concern that "the inevitable least, must etablish that the impermissible tive job performance." This elevation of the focus on statistics in disparate impact cases factor played a "susbstantial" role in the de- degree of justification required from busi- could put undue pressure on employers to liberative process before the employer is nesses squarely conflicts with. prior Su- adopt inappropriate prophylactic meas- burdened with the requirement of proving preme Court decisions, which have held ures," such as quotas. Watson, 108 S. Ct. at that permissible factors dictated the same that manifestly job-related selection criteria 2787. The articulation of adverse impact result. As Justice O'Connor noted, this re- do not have to be essential or absolutely re- analysis in Wards Cove was carefully de- quirement is supported by the consensus of quired in order to be sustained. Davis, 426 signed to ensure that this concern did not circuit courts that have addressed this issue, U.S. at Beazer, 440 U.S. at In come to fruition. which had uniformly required proof that addition, it runs directly into the problem Section 4, on the other hand, places busi- discriminatory factors "played a significant identified in Furnco of requiring courts to ness planners in the dilemma of having to or substantial role in the contested employ- assume the difficult, indeed impossible, choose between quotas and the legal re- ment decision" before shifting the burden burden of ascertaining what hypothetical quirement of proving that each and every of proof to the defendant. Id. at 1804 (quot- practices would be essential to a given busi- aspect of the employment process, in addi- ing the Court of Appeals; decision below in ness. tion to the overall process itself, is not only Hopkins V. Price Waterhouse, 825 F.2d 458, Third, by placing the burden of persua- reasonable and manifestly related to bona 470 (D.C. Cir. 1987)). sion upon defendants to establish the neces- fide job requirements but is also essential or Section 5 of the bill differs from Price Wa- sity or indispensability of their business indispensable. The sponsors of S. 2104 give terhouse in two principal ways. First, its use practices, Section 4 would relieve the plain- no explanation to how this latter standard of the term "motivating factor" appears to tiff. indeed even the court, of determining can be met, much less any evidence that it conflict with the requirement that the al- whether there are any alternative practices can ever be met. Nor is there any legal leged impermissible factor must have been a that would have a lesser impact on minority precedent explaining how an employer can substantial or significant factor in the em- groups. Instead, Section 4 would impose prove that common employment practices, ployment process. Thus, a plaintiff can es- upon the defendant the burden of establish- e.g., relying on job recommendations, or su- tablish a prima facie case by showing that ing that there is no possible alternative to pervisory evaluations, or the overall employ- the impermissible factor played a role in the the way its business is operated that might ment process itself, are essential. Thus, at a minds of any person involved in the deci- lessen the adverse impact upon protected minimum, employers without an effective sional process, no matter how insignificant groups. quota system in place would face unpredict- the role may be. There is simply no reason In this regard, it is interesting that propo- able and extremely risky prospects of litiga- to shift the burfen of proof to the employer nents of S. 2104 attempt to justify its shift- tion. based on trivial or insubstantial evidence. ing of the burden of proof to the employer Effective business planning requires rea- Second, Section 5 goes substantially by observing the virtual impossibility of sonably accurate predictions about the legal beyond the position of Justice Brennan and proving a negative fact, i.e., the absence of effect of employment decisions. The legal his colleagues in Price Waterhouse. As noted any conceivable business justification for a uncertainties implicit in the defense burden above, Justice Brennan's plurality decision challenged practice. As the foregoing indi- imposed by Section 4 would deprive busi- permitted the defendant to absolve itself of cates, Wards Cove never imposed such an nesses of the ability to make such predic- any laibility if it could carry the substantial 3152 CONGRESSIONAL RECORD March 26, 1990 burden of proving that the prohibited. workplace. If employers are given prompt ployees to accept a reasonable settlement factor did not alter the ultimate decision. As notice of a problem by the early filing of a offer-the employee pays neither court written. Section 5 only allows-the defendant charge, they can correct it and provide reas- costs nor attorneys' fees while the Equal to reduce its financial exposure with proof nable compensation to any victims of dis- Employment Opportunity Commission han- that the impermissible motive had no actual crimination. Without prompt notice, the dles the charge. Claims are not likely to be effect on the employment decision in ques- problem may go uncorrected, and employ- tion. The defendant would still be found er's back pay liability will be increased un- settled where there is such a significant liable for employment discrimination and justifiably. Moreover. by unnecessarily ex- "upside" and no corresponding "downside" to litigating. required to pay the plaintiff's legal fees no panding an employer's back pay liability, matter how strong its evidence that the this extended limitations period may well Recent experience in California has plaintiff was not denied any employment impede another fundamental purpose of shown that the availability of compensatory opportunity for a prohibited reason. Title VII-conciliation and settlement of and punitive damages turns employment This latter result of Section 5 is a dramat- cases. litigation into a high-stakes lottery in which ic alteration of Title VII. As originally en- Title VII's 180-day limitations period has everyone-employees, employers, and the acted, it was clear that Title VII only pro- served both employers and employees well courts-loses. Once compensatory and puni- hibited discriminatory actions, not for over 25 years. The same 180-day rule ap- tive damages became available in California, thoughts. As Justice O'Connor observed, in plies under the National Labor Relations wrongful discharge litigation went out of response to claims that Title VII would Act and has succeeded in protecting employ- control. The courts were overwhelmed with becomes a "thought control bill," the influen- ee rights under that Act for more than 50 cases, and juries seemed to lose touch with tial Senator Case stated that "There must years. We are aware of no public outcry or reality. Between 1980-1986, employees won be some specific external act, more than a need for á change in Title VII's statute of more than 70 percent of the cases tried mental act. Only if he does the act because limitations and fail to see any benefit from before juries, and the average award was of the grounds stated in the bill would there this dramatic and unwise change. more than $545.000.' Million-dollar verdicts be any legal consequences." 100 Cong. Rcc. D. Section 8: Remedies to,single plaintiffs were not uncommon, and S 7254 (1964). Section 5 would impose a one verdict in Santa Clara County exceeded Although the sponsors of this bill-claim finding of liability and attorney's fees upon $50 million. Haun V. NEC, Case No. that it represents merely a "technical resto- employers even in the absence of a finding (1986). Punitive damages com- ration" of the law and an attempt to fill that any employment decision was brought prised a big part of these awards. The aver- "gaps" in the law, in fact Section 8 consti- about by illegal motivation. age 'punitive damage award was over tutes a wholesale revision of Title VII's en- Finally, from a business perspective, busi- $520,000. Rand Study at p. 25; see also Stem- forcement provisions by providing for jury nesses cannot control the thoughts of each ming the Tide at p. 406 (the average puni- trials as well as awards of both compensato- and every employee involved in the decision tive damages award in 'I982-1986 was ry and punitive damages. The rationale for making process. The best an employer can $494,000). In recognition of the problems this radical change is to "make the remedies do is to establish an employment process that these irrational verdicts created, the available for sex, religion and ethnic dis- that, through an effective system of checks California Supreme Court recently deter- crimination claims under Title VII the same and balances, prevents decisions from being mined that compensatory and punitive dam- as the remedies now available under Section made for illegal reasons. If an employer is ages should not be recovered in most wrong- 1981 for racial discrimination." This ill-con- successful in this endeavor, it should be re- ful discharge cases. Foley V. Interactive ceived attempt to alter dramatically the warded, not penalized, by the law. Data, 47 Cal. 3d 654'(1988). Title VII landscape should be rejected. C. Section 7: Statute of Limitations A major problem with punitive damages is There is no good reason why the remedies available under Title VII should mirror the the lack of any guidance to juries as to Although advertised as a response to Lor- when and in what amounts punitive dam- ance V. AT&T Technologies, 109 S. Ct. 2261 remedies "available under Section 1981. (1989), Section 7 of the bill represents a Indeed, the opposite is true-there are good ages should be awarded. As Professor Gould noted, "Juries in these cases often impose 11- major rewrite of Title VII by allowing a reasons why the remedies should differ. Sec- charge to be filed at any time within two tion 1981 is not coextensive in its coverage ability and large damage awards according years of the time an unlawful practice oc- with Title VII. Section 1981 covers only to their own standards of fairness rather curred "or has been applied to affect ad- racial discrimination and is applicable to all than the legal instructions provided by the employers; while Title VII establishes a co- judge." Stemming the Tide at p. 406. This versely the person aggrieved, whichever is later." Under current law, charges must be ordinated mechanism for remedying em- creates not only greater uncertainties for filed within 180 days after an employee re- ployment discrimination. Unlike Section business planners but also great inequities ceives notice of an unlawful employment 1981, Title VII offers victims of discrimina- between successful plaintiffs who may re- tion assistance in investigating their claims, ceive widely varied awards based on similar practice. Delaware State College V. Ricks, competent counsel to represent them, and a conduct and harm. The standard articulated 449 U.S. 250 (1980). Sections 7(a)(1) and (a)(2) of the bill would dramatically extend waiver of court costs. This comprehensive in the bill do little to resolve this concern. Although the bill's standard tracks the Title VII's statute of limitations, without scheme is designed to facilitate prompt reso- any justification: Section 7(a)(1) would lution of employment disputes, with an em- standard articulated by the Supreme Court extend the time limits for filing a charge phasis onconciliation and settlement. Sec- in Smith V. Wade, U.S. 30 (1983), it pro- from 180 days to two years. Section 7(a)(2) tion 1981, on the other hand, merely pro- vides little guidance to courts or juries as to would extend that time limit even further vides a private right of action, without any when punitive damages should be awarded. by. starting the running of the limitations administrative support mechanism. These Indeed, because the bill adopts a' "reckless period at the time that the adverse action differences underlie the distinctions be- disregard of the rights of others" standard, impacts the employee, rather than the time tween the remedies available. Indeed, it was and because international discrimination that the employee has notice of the adverse on the basis of these differences that a necessarily involves a disregard of others' action. In essence, Section 7(a)(2) would unanimous Supreme Court first recognized rights, punitive damages would seem to be overrule Delaware State College V. Ricks. the availability of compensatory and puni- available in virtually every-case involving in- There is no basis for this dramatic exten- tive damages in Section 1981 actions. John- tentional discrimination. Surely, the spon- sion of Title VII's time limits. A primary son V. Railway Express, 421 U.S. 460 (1975). sors of the bill did not intend this result. goal of Title VII is the prompt resolution of As the court noted "the remedies available Compensatory and punitive damages are employment discrimination claims. This under Title VII and under Section 1981, al- simply a bad idea in Title VII litigation. By goal not only advances the potential for rec- though related, and although directed to producing unreasonably large verdicts, they onciliation and the reestablishment of a most of the same ends, are separate, dis- will increase the costs of goods and services: nondiscriminatory work relationship but tinct, and independent." Id. at 454 make the market less efficient, and reduce also diminishes the chance of harm to inno- Rather than efféctuating the purposes of the availability of jobs. They will encourage cent coemployees,- whose career and other the Title VII, the availability of compensa- employers to retain incompetent employees expectations are often built on prior em- tory and punitive damages will undermine for fear of litigation, thereby making the ployment decisions. Permitting an employee the Act's goals-by impeding the prompt work force as a whole less productive. These to wait for more than two years before resolution of employment disputes through are real, weighty concerns. As the Fole filing a charge of discrimination is wholly ,conciliation and settlement. The availability court recently noted, "the expansion of ter inconsistent with the goal of prompt resolu- of compensatory and punitive damages will remedies in the employment context has P tion of employment disputes. Moreover. it is provide an irresistible incentive to litigate. tentially enormous consequences for th simply unfair to permit an employee to wait Employees ar unlikely to accept reasonable to exercise a right while the memories of pretrial settlement offers if they know that witnesses fade; documents are lost or mis- there is a possibility that they will be 'J. Dertouzos, The Legal and Economic Conse quences of Wrongful Termination," Rand Corpors placed. and back pay is accruing. An individ- awarded a windfall in the form of punitive tion Study R-3602-ICJ (1988): ("Rand Study ual should not be permitted to "grow" po- damages if they go to trial. This is particu- Gould. Stemming the Wrongful Discharge Tide: tential back pay award while the employer larly. true under Title VII because the Case for Arbitration, 13 Emp. Rel. LJ. 404 USE goes without notice of problem, in the system contains no incentives for the em- ("Stemming the Tide"). March 26, 1990 CONGRESSIONAL RECORD - SENATE S 3153 stability of the business community.' 47 change apparently is intended to permit Cal. 3d at 669. Title VII to circumvent the holding of versed Indeed, we note that the Attorneys Moreover, punitive damages are at odds Marek V. Chesny. Thus, if Section 9 is en- General in more than 42 states, three pro- with a fundamental premise of Title VII+ acted. Title VII plaintiffs will be free to tectorates, and one major city filed amicus that victims of discrimination be compensat- reject Rule 68 settlement offers without any briefs supporting the result reached by the ed for the Injuries that they actually suffer. fear of the loss of attorneys' fees should court in Evans. V. Jeff D. That decision is Punitive damages are a windfall to plain- they not recover more than the offered correct and should be permitted to stand. tiffs, who are entitled to receive full com- amount at trial. Moreover although the bill's sponsors pensation for their injuries, but nothing This attempt to reduce the risk of rejec- suggest that Section 9(4) is limited to court more. Title VII currently provides victims of tion of a reasonable settlement offer is both ordered consent decrees, the language of discrimination with adequate compensation misguided and contrary to the purposes of Section 9(4) is not narrowly drawn. Section for their injuries and, thus, punitive dam- Title VII. As previously noted, one of the 9(4) refers to a "consent order or judg- ages are not necessary to fill any "gap." fundamental goals of Title VII is the ment." As drafted, It could easily be read to The proponents of compensatory and pu- prompt resolution of employment disputes apply to the settlement of any Title VII nitive damages argue that the availability of through conciliation and settlement. Sec- claim. For obvious reasons, this result would these remedies will have a desirable deter- be folly. Experience has shown that attor- tion 9 undercuts this goal by making rejec- rent effect: However, given the skyrocketing tion of reasonable settlement offers risk- neys' fees awards in single plaintiff Title costs of employment litigation, no further free to Title VII plaintiffs. It will also result VII actions often dwarf the amounts recov- deterrent is necessary Experience has in unnecessary, costly litigation. An individ- ered by plaintiffs. H. Newburg. Attorney Fee shown that the average cost of defending a ual should not be. permitted to recover at- Awards, ch. 11 (1986). Given this large expo- single plaintiff employment discrimination torneys' fees and costs for work performed sure, few defendants would be willing to action through trial can be between after rejection of a settlement offer where settle single plaintiff cases unless they could $100,000 and $150,000, and often it is much he does not recover more than the offered obtain. a waiver of any attorneys' fees more. Of course, the employer must also amount at trial. Under these circumstances, claims Thus, by foreclosing settlement of pay the employee's attorney's fees and costs the settlement offer would have fully com- fee issues as part of a package settlement, pensated the individual for his losses and Section 9(4) would greatly impede settle- if the employee prevails. Thus, an employer who discriminates is facing at least should have been accepted. Nor should de- ment of single plaintiff Title VII cases. The $200,000-$300,000 in litigation costs alone. fendants be required to pay attorneys' fees bill's sporisors surely cannot intend this result. This is more than ample deterrence for any to plaintiffs on amounts expended to prose- employer. cut post-offer claims because such claims II. CONCLUSION Finally. we note that this issue has recent- are, by definition, worthless. Thus, the The sponsors of S. 2104 avidly assert that ly been debated by the Senate in the con- changes proposed by Section 9 are unwise their bill is intended to overturn a number text of the Americans With Disabilites Act and unwarranted and should be rejected. of recent Supreme Court decisions and Γe, (ADA). For many of the reasons articulated The Chamber also has serious concerns store the law to its prior state. As the previ- above, Congress determined that compensa- about Section 9(4). Section 9(4) of the bill ous discussion demonstrates, however, this tory and punitive damages were not appro- would foreclose court approval of Title VII's bill would go much further. Indeed, S. 2104 priate in the employment discrimination settlements unless "a waiver of all or sub- represents a blatant effort to inject con- context. Indeed, Senator Durenberger ex- stantially all attorneys's fees was not com- cepts into the law that are directly in con- plained the elimination of the compensato- pelled as a condition of settlement The flict with the principles upon which Title ry and punitive damages provision from bill's sponsors argue that this section is in- VII was founded, including, most important- ADA as follows: tended to overrule Evans V. Jeff D., 475 U.S. ly, the principle of basing employment deci- We also took great effort to address the 717 (1986), and that it would simply bar sions on merit and merit alone. This effort concerns many had over the punitive nature "forced" waivers of attorneys' fees claims in to alter the fundamental precepts of Title of the remedies section. Instead of allowing consent. decree settlements. But the lan- VII law, as articulated by Congress and the punitive and compensatory damages as guage of Section 9(4) goes far beyond that Supreme Court since 1964, threatens to originally introduced, the bill before us modest objective and should: in any event. make humerical quotas the very artificial today parallels current civil rights legisla- be rejected. "masters of reality" originally condemned tion under Title II and VII of the Civil There is no good reason to overrule Evans in the Griggs decision. Rights Act of 1964 This change will help V. Jeff D. Contrary to the impression created The misguided notion that appears to un- avoid some of the excessive and unnecessary by the rhetoric supporting Section 9(4), derlie much of the bill is the conclusion that litigation the original bill would have Evans V. Jeff D. does not mandate "forced Title VII is not working well. However, caused. (Emphasis added). waivers" of attorneys' fees claims. In Evans. there is no empirical basis for this assump- Vol. 135 Cong. Rec. No. 112, S 10721 (Sept. V. Jeff D., the Supreme Court merely held tion. Moreover. anyone with even rudimen- 7. 1989) (Statement of Senator Duren- that a District Court has the power to ap- tary knowledge of the changes that Title berger). This approach was fully debated prove a consent decree settlement that in- VII has wrought in the American workplace and rejected last fall. and there is no reason cludes a waiver of attorneys' fees. Thus, knows that Title VII has been and contin- Evans V. Jeff D, does not stand for the prop- to reopen that issue here. ues to be a powerful vehicle for the eradica- osition that parties to a Title VII must E. Section 9: Attorneys fees waive their attorneys' fees; rather, it holds tion of employment discrimination. In light We have serious concerns about the bill's only that they may waive those claims. of this history of progress, it seems that the prime beneficiaries of the bill would be the attorneys fees provisions. First, Section 9 of Thus, plaintiffs and their counsel remain the bill will have a dramatic effect on settle- free to reject any settlement offer they lawyers who would reap potentially vast ment offers under Rule 68 of the Federal deem unreasonable. In addition, they may monetary rewards from the expanded incen- Rules of Civil Procedure. Rule 68 provides address limitations on the waiver of fees or tives for litigation that the bill provides. Most importantly, the changes to Title that if a timely pretrial offer of settlement the ultimate allocation of settlement pro- VII sought in this bill offend the basic is not accepted and "the judgment finally ceeds in the event of such a waiver in their premise of equality upon which our demo- obtained by the offeree is not more favor- retainer agreements. cratic and constitutional society is founded. able than the offer, the offeree must pay This is a sound, reasonable result. There is the costs incurred after the making of the no good reason for parties to Title VII liti- Although the substitution of quotas for merit can never be justified, it is particular- offer." The purpose of Rule 68 is to encour- gation to be foreclosed from waiving attor- ly inappropriate in this time of intense and age voluntary settlements and relieve over- neys' fees claims as part of the negotiated growing international competition. The crowded court dockets by creating a disin- settlement. To the contrary. there are many touchstone of any national legislation to be centive to unreasonable rejections of fair good reasons for parties to be permitted to, passed by this or any ensuing Congress settlement offers. and perhaps encouraged to, waive fees should be the removal, not the creation: of In Marek V. Chesny, 473 U.S. 1 (1984). the claims during settlement negotiations. For artifical barriers to merit based on employ- Supreme Court held that a party who re- many Title VII actions, particularly those ment. jects a Rule 68 settlement offer and thereaf- seeking injunctive relief, the attorneys' fees ter is awarded less than the offered amount awards are the largest monetary exposure at trial cannot recover either fees or costs facing defendants. Obviously, to the extent STATEMENT OF DONALD B. AYER, DEPUTY Ar- for any post offer work, where the statute that plaintiffs are permitted to waive all or .TORNEY GENERAL, BEFORE THE COMMITTEE authorizing recovery of attorneys' fees de- part of those claims, Title VII actions will ON LABOR AND HUMAN RESOURCES, FEBRU- fines attorneys' fees as part of the "costs." be more easily settled. Indeed, foreclosing ARY 27, 1990 Title VII-currently defines attorneys fees as any waiver of attorneys' fees would often Mr. Chairman, distinguished members of part of the costs. 42 U.S.C. 2000e-5(k). By pose an absolute barrier to settlement. In the Senate Committee on Labor and Human striking out the phrase "as part of the" Evans V. Jeff D., the court recognized these Resources: from Title VII's costs provisions, Section problems and reached the correct result. We It is an honor to appear before you today 9(3) makes recovery of attorneys' fees inde- have heard no public outcry against that de- to testify regarding the U.S. Supreme pendent of the recovery of costs. This cision and fail to see why it should be ré- Court's rulings last term involving civil 3154 CONGRESSIONAL RECORD SENATE March 26, 1990 rights issues, and S. 2104, entitled the Civil The Court held that Section 1981 is limited Rights Act of 1990. The Administration has by its terms to prohibiting discrimination in precise litigation. In addition, a rule that a strong commitment to the civil rights of "mak[ing] and enforc[ing] contracts," and limits challenge to the period immediately all people. We believe that there must be does not extend to "problems that may arise following adoption of a seniority system will strong remedies to root out discrimination later from the conditions of continuing em- promote unnecessary and unfocused litiga- wherever it may exist. Unfortunately, ployment." Patterson, U.S. at tion. Employees will be forced to challenge 109 racism and bigotry cannot be viewed as S. Ct. 2372. Thus, the Court held, the stat- the system before it has produced any con- wholly problems of the past. As the Presi- crete impact, or forever remain silent. Other ute prohibits discrimination, whether gov- dent said in his State of the Union message: ernmental or private, in the formation of a employees, who are hired after the statute "Every one of us must confront and con- contract, and in the right of access to a legal has run following adoption of a seniority demn racism, anti-semitism, bigotry. and process that will enforce established con- system, will be barred from ever challenging hate. Not next week, not tomorrow, but tract obligations without regard to race. Ac- the adverse consequences of that system. re- right now. Every single one of us." cording to the Court, however, the plain- gardless how severe they may be. Such a We congratulate the Senate for passing, tiff's allegations of harassment on the job rule fails to protect sufficiently the impor- with Administration backing, the Hate addressed only conditions of employment tant interest in eliminating employment dis- Crimes Statistics Act, which, once enacted, and were not actionable pursuant to Section crimination that is embodied in Title VII. will help us to get a better picture of this 1981. The Administration therefore supports an problem and to focus our resources where The amicus brief filed by the Department amendment to section 706(e) of Title VII of they are most needed. In the first year of of Justice, on which my name appears, the Civil Rights Act of 1964 that would re- this Administration, the Department of Jus- argued for a somewhat broader reading of start the period for filing a charge each tice indicted some 89 defendants in 56 sepa- Section 1981, which would have extended its time an employee was injured by the appli- rate cases for criminal civil rights violations. coverage to claims of harassment that cation of a seniority system that was alleged We filed or participated. in 34 cases under would constitute a violation of state con- to have been adopted with disciminatory the new Fair Housing Act amendments, tract law. Our review of the cases applying intent. which only became effective as of March 12. Patterson over the last eight months fur- We urge Congress to move quickly to And we filed & dozen employment discrimi- ther leads us to the, conclusion that the enact these two important changes. At the nation cases. As our activities suggest, we Court's reading leaves a gap in the fabric of same, we strongly believe that four other are using vigorously the tools available to us our civil rights laws that must be filled. We major changes proposed by S. 2104 should and, for the most part, we find those tools therefore support corrective legislation to not be adopted. We are convinced that three effective. ensure that section 1981 will apply to the of last Term's decisions, Wards Cove Pack- The Supreme Court last Term issued some performance, breach, and termination of ing Co. v. Atonio, - U.S. 109 S. Ct. 2115 thirteen decisions that touched one aspect contracts to the same extent that it does to (1989); Martin v. Wilks, - U.S. 109 S. Ct. or another of civill rights law. In some of their making and enforcement. At the same 2180 (1989); and Price Waterhouse U. Hop- these cases, the government had urged the time, we believe that it is appropriate to kins, - U.S. 109 S. Ct. 1775 (1989), position adopted by the Court. In others, codify the holding of Runyon V. McCrary, should be left Intact. the Court disagreed with the government. 427 U.S. -160 (1976), that section 1981 pro- In Wards Cove, the Court addressed three Thereafter, the President and Attorney hibits private, as well as governmental dis- Important issues concerning the burdens of General both pledged last June that the Ad- crimination. proof in a lawsuit alleging that an employ- ministration would carefully monitor the In Lorance, supra, female employees chal- er's hiring practices have had the effect of application of these decisions in the lower lenged a seniority provision pursuant to discriminating in violation of Title VII. courts to determine their effect on meritori- Title VII, claiming that it was adopted with After reaffirming that statistics may-form ous civil rights claims and respond accord- an intent to discriminate against women. Al- the basis for a prima facie case of disparate ingly. though the provision treated all similarly impact, and that the statistics must com- We have done exactly that Based on our situated employees alike, it produced demo- pare the employer's workforce to the pool own studies and comments from groups, in- tions for plaintiffs, who claimed that the of qualified job candidates, the Court ad- cluding the NAACP Legal Defense and Edu- employer had adopted it with the intent to dressed the issue of causation. The Court cation Fund, we have concluded that of the discourage women from entering a particu- held first that a plaintiff must identify the five most significant decisions, two reach re- lar line of employment. specific employment -practices that have sults that merit legislative action. Thus, we The Supreme Court held that the claim produced the challenged disparate impact. believe that Congress should amend the law was barred under Title VII's statute of limi- Thereafter, the Court addressed the bur- to require a different result from that tations, because the time for plaintiffs to dens imposed on the parties once a plaintiff reached by the Supreme Court in Patterson file their complaint began to run when the has established a prima facie case of dis- V. McLean Credit Union, U.S. employer adopted the allegedly discrimina- crimination. It held that the employer's 109 S. Ct. 2363 (1989), and Lorance V. AT&T tory seniroity system. The Court distin- burden is to. produce evidence that the Technologies, Inc., U.S. 109 S. guished. the -situation where a seniority "challenged practice pursues, in a signifi- Ct. 2261 (1989). Accordingly, the Adminis- system discriminates on its face, acknowl- cant way, the legitimate employment goals tration supports legislation that has been edging that in such a circumstance each ap- of the employer." Wards Cove, - U.S. introduced by Senators Thurmond, Dole, plication of the policy constitutes a new vio- 109 S. Ct. at 2125-26. Finally. the Court Hatch and Coats (S. 2166) to address the lation. However, where, as in the case before held that the burden of persuasion always problems created by these cases. With it, the provision is neutral on its face (al- remains with the plaintiff, and that the regard to three other cases, based on our though discriminatory both in purpose and plaintiff may defeat the. employer's evi- review of how these rules have been ap- effect). the Court concluded that only the dence by showing that reasonable alterna- plied.' we see no need for corrective action. initial enactment constitutes a violation. tives would serve the employer's purpose In supporting legislative action in some The United States, and the EEOC. filed equally well. areas and opposing It in others, we are an amicus brief. on which my name ap- This seems to us to be a sensible and effi- guided by a fundamental principle that peared, supporting the plaintiffs. We argued cient allocation of litigation responsibilities. grows out of our history, and is now a part that the plaintiffs' demotions were not Asking the plaintiff to identify. the specific of the fabric of our law: that people should merely the inevitable effects of the prior al- practices that produce a disparate impact not be judged or dealt with according to the legedly discriminatory adoption of the se- before employers are asked to justify them color of their skin or certain other irrele- niority system. but were instead direct, is consistent with traditional rules allocat- vant personal traits. We take this as a present applications of the seniority system, ing burdens of proof. This allocation of re- common value that all decent people can the effects of which had until then been sponsibilities strikes us as more efficient agree upon. I will begin by discussing those only theoretical, and, as such, were "unlaw- than allowing plaintiffs simply to allege areas where we think this principle dictates ful employment practices" that independ- that a hiring system produces a disparate the enactement of new legislation. ently triggered Title VII's statute of limita- impact and forcing employers to demon- In Patterson, supra, an employee brought tions. strate that each individual employment an action pursuant to 42 U.S.C. 1981. alleg- The rule adopted by the Court could have practice within that system does not have a ing that her employer has harassed her on the result of shielding intentionally dis- disparate impact. In view of the liberal dis- the job. failed to promote her. and ultimate- criminatory seniority systems from attack covery rules and the record-keeping require- ly discharged her, all because of her race. by.people who never have had an opportuni- ments of the Uniform Guidelines on Em- ty to challenge them. The discriminatory ployee Selection Procedures, 29 C.F.R. reasons for adoption of a seniority system § 1607.1 et seq. (1988). we do not think that 1 These decisions are Wards Cove Packing Co. V. may become apparent only when the system this requirement of specificity should Atonio. U.S. 109 S. Ct. 2115 (1989): Martin is finally applied to affect the employment unduly burden plaintiffs. V. Wilks. U.S. 109 S. Ct. 2180 (1989): and Price Waterhouse V. Hopkins. U.S. 109 S. status of the employees that it covers. More- Indeed, the Court's prior "disparate Ct. 1775 (1989). We also oppose any legislation over, such an application surely focuses the impact cases have always focused on the aimed at City of Richmond V. J.A. Croson Co., controversy between an employer and an impact of particular hiring practices on em- U.S. 109 S. Ct. 706 (1989). employee more sharply and permits more ployment opportunities for minorities,' March 26, 1990 CONGRESSIONAL@RECORD SENATE 3155 Wards Cove, U.S. at 109 S. Ct. 2124, lateral attack doctrine, pursuant to which and plaintiffs have always targeted those based solely:o the discriminatory thoughts some courts had held that once a decree was of an agent of the employer, which have no specific practices. See Griggs v. Duke Power entered, it could not be challenged, even by Co., 401 U.S. 424 (1971) (high school diplo- consequence to the plaintiff. For: contrary individuals who had not been parties to the to the Court's conclusion that Title VII is ma requirement); Dothard v. Rawlinson, original lawsuit. not violated where the employer proves that 433 U.S. 321 (1977) (height and weight re- The Court's decision turned on a straight- the adverse action would have resulted even quirements for prison guards); Albemarle forward application of the Federal Rules of in the absence of any discriminatory motive, Paper Co. v. Moody, 422 U.S. 405 (1977) (em- Civil Procedure and underlying notions of the proposed legislation recognizes a viola- ployment tests and seniority systems); Con- due process. The Federal Rules establish tion and a damage remedy in that circum- necticut v. Teal, 457 U.S. 440 (1982) (written procedures for joinder of all interested par- stance. I believe that this would be the first examination); Watson v. Fort Worth Bank ties in a case. Under those procedures, instance ever in American law where dam- & Trust, 487 U.S. 977 (1988) (subjective anyone who is not joined in a lawsuit, and ages could be recovered solely for thinking judgment of supervisor). given an opportunity to appear in court to bad thoughts. In our view, the Court also correctly held protect his or her rights, cannot be bound We also need to be clear on one other that its formulation of the applicable sub- by the final judgment. The Court's decision point. As this Committee is aware, the Presi- stantive standard is fully justified as an ap- is a reaffirmation of the fundamental dent, and the Attorney General have propriate balancing of the interests of em- notion that everyone, regardlessof race or strongly supported the Americans With Dis- ployers and employees. Courts have used gender, it entitled to his or her day in court. abilities Act (ADA), and have worked closely varying terminology in defining that stand- The Department of Justice advocated the with Congress, and the disability communi- ard. The standard molded by the Court position adopted by the Court. I did not ty to devise the version that passed the from those prior formulations has sufficient work on that brief, but I signed a similar Senate with Administration support. I was teeth to ensure that employers do not use brief arguing the same approach a year not personally a party to that process. Ac- practices of dubious business utility, while erlier in Marino V. Ortiz, 484 U.S. :301 cordingly, others are in a better position to not pressuring employers to resort to hiring (1988). answer detailed questions concerning it. and promotion quotas, and respecting the We think tht this decision should have a However, I do think it is important to make needs of employers to preserve legitimate salutary effect. By requiring early joinder of the following point. management prerogatives. We find it un- all those who may be adversely affected by Title I of the ADA, as agreed to, dealing likely that this formulation of the standard a lawsuit, the decision should enable courts with employment, incorporates by reference for a business justification will preclude the to consider the fully range of interests af- remedies available under Title VII. It was assertion of meritorious claims, particularly fected by a proposed decree. The decision very clear at the time of our discussions since the plaintiff may still prevail by show- should lead to fairer, more carefully consid- that the fact that these remedies were limit- ing that other reasonable business practices ered, and unassailable remedies for discrimi- would satisify the employer's need without nation. It will discourage defendants from ed to injuctions, back pay, and other equita- producing a discriminatory effect. settling discrimination cases by bargaining ble relief that can be obtained without trig- Likewise, we think that the burden of per- away third party rights, rather than making gering the Constitution's civil jury require- ment was critical to the Administration's suasion remains with the plaintiff through- whole the actual victual victims of discrimi- out a disparate impact case, just as it does in nation: In addition, the participation of all agreement. a case alleging intentional discrimination, of the affected parties in formulation of a In light of the fact that legislation alter- see Texas Department of Community Affairs decree should aid in its implementation. ing these remedies has now been intro- Successful, voluntary compliance with Title duced, our continuing support for the ADA V. Burdine, 450 U.S. 248, 256-58 (1981), and VII may depend upon the cooperation of a hinges on the clarification that the reme- just as it generally does when causation is an element of a violation. See Restatement broad range of individuals. Involving as dies provisions of the ADA will not be af- (Second) of torts § 433B (1965). We think it many of those individuals as possible in for- fected by the proposed Kennedy-Hawkins would be unjustifiable to impose a greater mulating the decree will lead to smoother amendment of the remedies available under burden on an employer who is alleged to and more effective implementation of the Title VII. This will require amending the have violated Title VII by employing a prac- remedy for discrimination reference to Title VII in the Senate version tice that produced a disparate impact than The proposed legislation relating to Wilks of the ADA: We look forward to cooperating on one who is alleged to have engaged in would reverse, in the context of civil rights with this Committee and others to assure purposeful discrimination. consent decrees, the usual practice under that the goal of bringing 43 million disabled We are convinced that the Court thought- our system of civil litigation. Instead of re- Americans into the mainstream of American fully balanced the competing interests and quiring that outsiders be joined by the par- life through passage of the ADA, a goal that produced a workable distillation of some ties to litigation if they are to be bound, the we all share, is not thwarted by disagree-. legislation would put the burden on outsid- ments about other areas of the law. eighteen years of precedents applying the disparate impact standard. Indeed, the ers to inject themselves into a dispute be- In summary. we believe that the Supreme Court in large part adopted the approach tween others. Persons with no current inter- Court acted prudently and correctly, and in urged by a brief filed by the United States. est in issue must be on the lookout for on- reasonable interpretation of existing stat- We believe that plaintiffs will be able to going litigation whose resolution may at utes and case law, in its decisions in the pursue successfully meritorious claims, and some point impact upon them. Wards Cove, Wilks, and Price Waterhouse employers will not be unduly burdened in Neither the burden on these non-litigants decisions. These decisions should be allowed defending claims of discrimination and will to join or be bound, nor the burden on the to stand. not be encouraged to resort to quotas to judicial system of such expanded and unfo- At the same time, with regard to Patter- ward off the threat of lawsuits based on cused lawsuits, is wise as a matter of policy. son and Lorance, we urge Congress to act statisical imbalances. Nor do we believe that it is fair to bind, as quickly to enact our proposals. It is appar- At the same time, we believe strongly that the proposed bill does, anyone who has ent that the Administration and the spon- the changes proposed in S. 2104 would have actual notice of the lawsuit, or who lacks sors of S. 2104 are in substantial agreement serious adverse consequences. By altering actual notice but whose interests are ade- on these issues, and we propose that S. 2166, all three of the conclusions reached by the quately deemed protected by others, or, fail- the Administration's Bill. therefore be acted Supreme Court, and placing on the employ- ing that, wherever "reasonable efforts" are upon expeditiously. er the ultimate burden of identifying his made to give actual notice. Indeed, we be- I would be pleased to respond to any ques- own practices leading to a statisical imbal- lieve that serious due process issues are pre- tions. ance and proving them to be "essential" to sented. the conduct of his business, the proposal In Price Waterhouse V. Hopkins; TESTIMONY OF DAVID A. MADDUX, THE NA- puts an employer in a. nearly impossible po- U.S. 109 S. Ct. 1775 (1989). the Court TIONAL RETAIL FEDERATION. BEFORE THE sition. It would be difficult for an employer ruled in favor of a woman who alleged that COMMITTEE ON LABOR AND HUMAN RE- not to adopt a silent practice of quota hiring she had been denied partnership by her ac- SOURCES, FEBRUARY 27; 1990 and promotion in an effort to protect him- counting firm on account of her sex. In that Mr. Chairman and Members of the Com- self from the real probability of litigation case, the Court faced a so called mixed mittee: and liability wherever a statistical imbal- motive case in which plaintiff alleged that I am David A. Maddux. a Partner in the ance is shown. her sex had supplied part of the motivation law firm of Sheppard. Mullin, Richter & Martin V.1 Wilks, supra, arose in the con- for her rejection for partnership. The Court Hampton. I have represented employers in text of a civil rights action, but it turned on held that once she had established by direct labor and employment law matters for the principles of fairness and access to court and substantial evidence that sex played a past thirty years. I started practicing law in that apply in every area. The Court held part in the decision, the burden shifted to 1959, which was the year in which the State that firefighters, who had not been parties the employer to show that it would have of California enacted its California Fair Em- to a consent decree that mandated racial reached the same direction had sex not been ployment Practices Act which prohibited preferences. could have their day in court to considered. discrimination in employment. A substantial contend that the decree violated their civil The proposed legislation takes the star- portion of my practice at all times since has rights. The Court rejected the so called col- tling step of allowing a damage recovery involved employment discrimination mat- 3156 CONGRESSIONAL RECORD SENATE ters before both the California Fair Em- March 26, 1990 ployment and Housing Commission, the nonwhites, Filipinos and Alaska Natives) Equal Employment Opportunity Commis- with that of the employer's non-cannery in which the Supreme Court held that an sion, State Courts and United States Dis- work force (composed primarily of whites). employer could not avoid liability in a dis- trict Courts. The Supreme Court easily indentified the parate impact case simply by relying upon I appear on behalf of the National Retail logical fallacy associated with the lower the "bottom line," racially balanced result Federation 'I am Chairman of its Subcom- court's reasoning: "Most obviously. with re- of an allegedly discriminatory promotion mittee on Wage, Hour and Equal Employ- spect to the skilled non-cannery Jobs at practice. In Teal, one part of the promotion ment Opportunity Law. issue here, the cannery work force in no process involved 8 test which had a dispar- The National Retail Federation is the na- way reflected 'the pool of qualified job ap- ate impact on minorities. Analogously, in tion's largest trade group which speaks for plicants' or 'the qualified population in the Wards Cove, the Supreme Court held that employees who challenge an employment the retail industry on matters of govern- labor force." 109 S. Ct. at 2122 (emphasis in practice should not be able to establish a mental and public policy. Created by a original) disparate impact case simply by showing recent merger between the American Retail Its holding on this point is entirely con- racial imbalance "at the bottom line." Federation and the National Retail Mer- sistent with Hazelwood School Dist V. The point is simple. If an employer cannot chants Association, the organization repre- United States, 433 U.S. 299, 308 (1977), in avoid liability by resting upon a favorable sents the entire spectrum of retailing, in- which the Supreme Court held that the "bottom line" result, an adversely affected cluding 27 national and 50 state retail asso- 'proper [statistical] comparison [in a dis- employee should not be able to prove liabil- ciations. In addition, the Federation mem- bership encompasses over one million U.S. parate impact case is] between the racial ity solely by showing an unfavorable retail establishments employing nearly 16 composition of [the at-issue jobs] and the bottom line" result. The real issue is racial composition of the qualified whether a particular employment practice million people and accounts for more than pop- one-quarter of the GNP. ulation in the relevant labor market." Simi- or selection device has a prohibited effect I greatly appreciate this opportunity to larly, in New York City Transit Authority V. on the protected class. It will be impossible Beazer, 440 U.S. 568, 585 (1979)2, the Su- for the Courts to properly decide this issue appear before you and testify on the Civil if the plaintiffs can continue to hide it. Rights Act of 1990. The views I will express preme Court held that in the absence of re- Furthermore, the Wards Cove Court's are based primarily upon my years of expe- liable labor market statistics, the courts holding that the burden of proof remains rience representing retailers, many of whom may look to statistics that measure the with the disparate-impact plaintiff at all are members of the National Retail Federa- racial composition of "otherwise-qualified times is perfectly consistent with prior tion, in employment discrimination matters. applicants" for the at-issue jobs. precedent. See, e.g., Watson D. Fort Worth The Bill has been publicized as a response Secondly, Wards Core perpetuated the Bank & Trust, 487 U.S. 977, 108 S. Ct. 2777, to recent "conservative" attacks by the Su- long-standing principle that in a disparate 2790 (1988) (O'Connor, J.); Texas Dep't of preme Court upon Civil Rights in employ- impact case the plaintiff must demonstrate Community Affairs v. Burdine, 450 U.S. 248, ment. In fact, its scope goes far beyond the the specific employment practice which is 256-58 (1981);5 Croker D. Boeing Co., 662 few recent decisions involving discrimina- claimed to have the disparate impact on F.2d 975, 991 (3d Cir. 1981). Section 4 of the tion in employment decided at the end of protected class members. The Court said: Bill will overrule these cases. It is also con- the last term. In reality it undoes and im- Consequently, on remand, the courts trary to Fed. Rule of Evid. 301, which clear- plicitly overrules a decade of the Court's below are instructed to require, as part of ly provides that a shift in the "burden of Title VII decisions. Much of the precedent respondents' prima facie case, a demonstra- going forward with evidence" does not which this proposed legislation will over- tion that specific elements of the petition- impose on a party "the burden of proof in turn was written and concurred in by the least conservative members of the Court. ers' hiring process have a significantly dis- the sense of the risk of non-persuasion, parate impact on nonwhites." 109 S. Ct. at which remains throughout the trial upon COMMENTS CONCERNING SECTION 4 OF THE BILL 2125 the party on whom it was originally cast." The practical effect of Section 4 will be to Section 4 of the Bill would undo Wards Curiously, the proposed amendment says codify and drastically alter traditional dis- nothing about a complaining party's option Cove by allowing a complaining party to es- under existing law to challenge a business parate impact analysis. Under the Act as tablish that an employment practice or "an amended, a complaining party could estab- necessity defense that has been put forth by overall employment process" (Section 3(o)) lish a prima facie case simply by demon- the responding party. This option is clearly is "unlawful" when it results in a disparate reaffirmed in Wards Cove In fact, it has strating that a "combination of employment impact upon a protected group. Since "over- practices or an overall employment process" been long established that the complaining all employment process" is such a broad party may attempt to prove that "other had a disparate impact upon a protected term, an employer could be found liable group. The employer would then have the tests or selection devices, without a similarly under the Act as amended based upon sta- undesirable racial effect, would also serve burden to produce evidence and prove by a tistical disparity that was simply accidental. the employer's legitimate [business] inter- preponderance of the evidence that the Requiring employers to defend against ests. Such a showing would be evidence practice or process in question was "essen- tial to [employees'] effective job perform- claims that unidentified employment prac- that the employer was using its tests merely tices violate Title VII places them in an im- as a 'pretext' for discrimination." Albemarle ance." No other "business necessity" could be used to defend the practice or process. possible position. In order to avoid liability, Paper Co. v. Moody, 422 U.S. 405, 425 (1975). At the same time, the plaintiff would have employers would have no option other than The Act as amended is silent regarding this no burden to demonstrate which practice to adopt strict racial quotas at all levels of element of traditional disparate-impact analysis. among a group of practices resulted in the their organization. This result was by no disparate impact. Instead, the employer means the original intent of Title VII. Albe- In addition, proposed Section 703(k)(2) marle Paper Co. V. Moody, 422 U.S. 405, 449 provides that "[a] demonstration that an would have the burden of producing evi- (1975). employment practice is required by business dence and proving with a preponderance of necessity may be used as a defense only the evidence that none of its practices or Wards Cove is also consistent with Con- against a claim under this subsection." The process had a disparate impact. necticut V. Teal, 457 U.S. 440 (1982) a case term "required by business necessity" is de- Section 4 of the Bill will also overrule fined in proposed Section 701(o) (Section 3 Wards Cove Packing Co. V. Atonio, 109 S. Ct. 2115 (1989) on the premise that it was Justice Stewart's opinion for the Court was of the Bill) as "essential to effective job per- incorrectly decided. To the contrary, Wards joined in by Chief Justice Burger and Justices formance." This definition severely limits Cove, as demonstrated herein, is entirely White, Marshall, Blackmun. Powell and Rehnquist, the business necessity defense in disparate consistent with long-existing judicial au- and concurred in by Justice Brennan. Justice Ste. impact cases. vens dissented. There are many instances in which em- thority interpreting Title VII. "Justice Steven's opinion for the Court was ployers have non-discriminatory business In Wards Cove, the Supreme Court began joined in by Chief Justice Burger and Justices reasons for taking job action. It would be its opinion by reaffirming that in order to Blackmun, Stewart and Rehnquist. Justice Powell concurred in part and dissented in part. Justices highly intrusive and simply bad public make out a statistically-based prima facie disparate impact case, the plaintiffs must Brennan, White and Marshall dissented. policy to inflict liability upon employers by prove there is a disparity between the racial , Justice Stewart's opinion for the Court was restricting the "business necessity" defense joined in by Justices Douglas and Brennan and con- to situations in which the employment prac- composition of the qualified persons in the relevant labor market and the persons hold- curred in by Justices Marshali and Rehnquist. Jus. tice is "essential to effective job perform- tice Blackmun concurred in the judgment. Chief ing the jobs at issue. ance." For example, If the Bill is passed in Justice Burger concurred in part and dissented in its present form. employers could be liable The lower court in Wards Core had erro- part. Justice Powell took no part in the consider- neously permitted the employees to make ation or decision of the case. thereunder whenever they effect a reduc- out a prima facie disparate impact case by Justice Brennan's opinion for the Court was presenting statistics which compared the Joined in by Justices White. Marshall, Blackmun Justice Powell wrote the opinion for a unani- racial composition of the employer's can- and Stevens. Chief Justice Burger and Justices mous Court composed of Chief Justice Burger. and Rehnquist and O'Connor joined Justice Powell's nery work force (composed primarily of dissenting opinion. Justices Brennan, Stewart, White, Marshall, Black- mun, Rehnquist and Stevens. March 26, 1990 CONGRESSIONAL RECORD SENATE S 3157 tion in force for economic reasons that re- sults in a disparate Impact upon protected cannot predict, as it sits here today, the many situations in which an employer may ing a fact by a preponderance of the evi- employees. Thus, a race-neutral reduction have legitimate nondiscriminatory business dence is met when the person having the in force could be cast pursuant to proposed or public policy reasons for adopting em- burden persuades the trier of fact that it is Section 703(k)(1)(A) as an "employment ployment practices that may have a dispar- more likely than not that the asserted fact practice" resulting in a disparate impact on is true. ate impact upon one group or another. the "basis of race, color, religion, sex, or na- Transportation Management was in tional origin." This would be true even if, COMMENTS CONCERNING SECTION 5 OF THE BILL accord with and relied upon in the United for example, the reduction in force arose The practical effect of Section 5 of the States Supreme Court's decision in Mt. from contracting out a function which re- Bill is to provide that a violation of the Act Healthy City Board of Education v. Doyle, sulted in a large savings for the employer. is established when the complaining party 429 U.S. 274 (1977), which dealt with the In one recent case, Spaulding V. Universi- demonstrates that a prohibited practice was discharge of a teacher and the board of edu- ty of Washington, 740 F.2d 686, cert. denied, a motivating factor of any employment deci- sion even though the decision was motivat- cation's refusal to reinstate him for his ex- 469 U.S. 1036 (1984), certain past and present members of the University of Wash- ing by other factors. The Section further ercising his constitutionally-protected right provides that if the responding party, usual- to free speech. The Supreme Court found ington School of Nursing faculty challenged the University's compensation practices ly the employer, "establishes" that it would that the trial court had erred by not deter- under 42 U.S.C. § 1983, the Equal Pay Act have taken the same action in the absence mining whether the board had shown by a of any discrimination, then the complaining preponderance of the evidence that it would and Title VII of the Civil Rights Act of party would not be entited to such remedies have refused reinstatement in the absence 1964. The plaintiffs alleged the University's as reinstatement and back pay. of the teacher's protected conduct. compensation practices discriminated against them on the basis of sex. On the other hand, even though the re- Thus, Price Waterhouse U. Hopkins, in de- The Court of Appeals affirmed the lower spondent establishes that it would have ciding that once a plaintiff in a Title VII taken the same action in the absence of any case shows that his or her protected status court's dismissal of plaintiffs' claims in part on the ground that the employer was con- discrimination, under Section 8 of the bill it played a motivating part in an employment will still be liable to the complaining party decision, the defendant may avoid a finding strained by market forces in setting its for general compensatory damages (includ- of liability only by proving that it would wages. The court opined: "For Title VII purposes, simply labelling ing pain and suffering and damages for have made the same decision even if it had an employer's action 'policy or practice' is emotional distress) and punitive damages, not allowed the protected status to play all of which can be awarded by a jury. such a role, was simply swimming in the not sufficient. What matters is the sub- This Section has been apparently pro- mainstream of long-standing judicial au- stance of the employer's acts and whether posed to reverse the effect of the United thority on this issue. those neutral acts are a non-job-related pre- text to shield an invidious judgment. [1] States Supreme Court dicision in Price Wa- Indeed, the Hopkins opinion was written Every employer constrained by market terhouse V. Hopkins, 109 S. Ct. 1775. (1989). by Justice Brennan and joined in by Jus- It would however, in reality, change the law tices Marshall, Blackmun and Stevens. Jus- forces must consider market values in set- ting his labor costs. Naturally, market prices of the land as it has existed in "mixed tices White and O'Connor concurred. Chief motive" employment discimination cases for Justice Rehnquist and Justice Scalia joined are inherently job-related, although the many years, and would impose on defendant Justice Kennedy's dissenting opinion. The market may embody social judgments as to the worth of some jobs. Employers relying employers the burden of general compensa- Hopkins plurality joined unanimous courts on the market are, to that extent, 'price tory and punitive damages in circumstarices in Mt. Healthy, an opinion participated in by takers.' They deal with the market as a where no liability at all would have been Chief Justice Burger and Justice Brennan, given, and do not meaningfully have "a imposed under longstanding legal prece- Stewart, White, Marshall, Blackmun, 'policy' about it in the relevant Title VII dent. Powell, Rehnquist and Stevens and Trans- sense. Fringe policies, which are discretion- The so-called "mixed motive" doctrine portation Management, an opinion partici- ary, are altogether another matter. Addi- arose in the context of Section 8(a)(3) of pated in by all of the above-named Justices tionally, allowing plaintiffs to estabish rell- the Labor Management Relations Act which except Justice Stewart who was succeeded ance on the market as a facially neutral made it unlawful to discriminate against by Justice O'Connor in the Court's October policy for Title VII purposes would subject employees based on their union activities or 1981 Term. employers to liability for pay disparities sympathies. The National Labor Relations Thus, it is respectfully suggested that it with respect to which they have not, in any Board in Wright Line, Inc., 251 NLRB 1083, would be the wrong result to impose the meaningful sense, made an independent 105 LRRM (BNA) 1169 (1980), enforced, 662 threat of serious monetary liability arising judgment." 740 F.2d at 708. F.2d 899 (1st Cir. 1981), cert. denied, 455 from general compensatory and punitive As the Ninth Circuit readily recognized in U.S. 989 (1982), held that the General Coun- damages on employers who would have Spaulding, uncontrollable market forces can sel of the National Labor Relations Board taken the same action but for the alleged result in actions by an employer that have a had the burden of proving that the employ- discriminatory motive, in the face of hold- disparate impact upon a protected class of ee's protected conduct was a substantial or ings requiring a contrary result by all of the employees. Under the amended Act, howev- motivating factor in the employees dis- Justices who decided Transportation Man- er, the University of Washington would charge. The Board then held that if there agement, ML Healthy and Hopkins. probably be found liable, withstanding the was another legitimate reason for the dis- In addition, there is a question concerning fact that It engaged in no "act" with respect charge the employer could avoid a violation what burden The Bill proposes to place on to the complaining parties. This result is of the Act by proving that the discharge the defendant by its use of the word "estab- even more certain given the vague and rested on the employee's unprotected con- lishes" in describing the employer's burden overly broad definition of "group of employ- duct, and that the discharge would have oc- in Section 5(b) of The BIll. In the defini- ment practices" as "an overall employment curred in any event. tions section the term "demonstrates" is de- process." Proposed Section 701(n) (Section 3 The National Labor Relations Board's fined. "Establishes" is not. of the Bill). Wright Line principle was given express ap- It is also respectfully suggested that it is Another example arises from Wambheim proval by the United States Supreme Court an inappropriate allocation of judicial re- V. J.C. Penny Co., Inc., 705 F.2d 1492 (9th in NLRB v. Transportation Management sources to process burdensome and time- Cir. 1983) in which the Ninth Circuit consid- Corp., 462 U.S. 393 (1983). In Transporta- consuming jury-trial litigation where the ered whether or not Penny's "head-of- tion Management, the Court held that even facts would clearly establish that the em- household" rule which allowed employees though the General Counsel of the Board ployer had a legitimate business reason for to obtain medical and dental insurance for a met his burden by proving that the employ- its employment decision which would have spouse if the employee earned more than ee's protected conduct was a substantial or been made irrespective of the plaintiff's pro- half the couple's. combined income violated motivating factor in the discharge of the tected status. Title VII. employee, the employer could avoid a viola- One could conjure the simple example of Although the rule clearly had a disparate tion of the Act by proving by a preponder- two employees who conspired in a common impact on female employees the court af- ance of the evidence that the discharge scheme to steal from their employer. Once firmed the trial court's decision that the rested on the employee's unprotected con- the employer found out about the scheme, major cost considerations involved estab- duct as well and that the discharge would he would probably terminate both employ- lished a legitimate business jurstification have occurred in any event. The Court, rely- ees. If a jury determined that the employer for the rule. ing on National Labor Relations Board happened to harbor some wholly unrelated The Bill as proposed would compel a con- precedent, characterized the doctrine as one feelings of prejudice against one of the indi- trary holding and the result would ignore where the employer could prevail by pre- viduals, who happens to be a protected class the economic realities of the situation. senting an "affirmative defense", which member. the likley and somewhat nonsensi- As these examples demonstrate, there is a under normal rules of burden of proof. cal result would be that he or-she would be plethora of situations in which preservation placed upon the employer the burden to entitled to recover general compensatory of a broader business necessity defense is sustain its affirmative defense by a prepon- and punitive damages. Of course, the equal- compelled by sound public policy. Congress derance of the evidence. The burden of prov- ly guilty non-protected employee would be 3158 CONGRESSIONAL RECORD - SENATE entitled to nothing. Clearly such a result March 26, 1990 has not logical support. the possibility of inconsistent results as be- tween judge and jury.6 affiliated with an additional 158,000 busi- COMMENTS CONCERNING SECTION 8 OF THE BILL COMMENTS CONCERNING SECTION 9 OF THE BILL nesses through its Associations Council and the National Industrial Council. The practical effect of the proposed The practical effect of Section 9 of the The Society for Human Resource Manage- mendment to Section 706(g) of the Act Bill is to prohibit a "waiver" of attorney's ment is the world's largest association for (Section 8 of the Bill) will be to provide for fees as a condition of settlement of a Title human resource professionals with over jury trials and compensatory and punitive VII action. As 8 result of proposed Section damages in cases of intentional discrimina- 706(k), it is likely that settlement of actions 44,200 members representing employers who employ over 53 million individuals. As tion. In this connection, It should be noted that have been commenced under the Act as the leading professional association for that essentially all individual disparate amended will be significantly discouraged. It human resource managers, SHRM has a treatment cases involve intentional discrimi- has long been the practice of parties in em- nation. The result of the proposed amend- ployment discrimination suits to combine a vital interest in legislation impacting on almost every aspect of the human resource ment will be to take federal discrimination settlement of all claims, as well as any attor- function ney's fees, into a lump-sum figure. General- cases out of the expert hands of the EEOC ly, the defendant provides the plaintiff and Both SHRM and NAM have a long back- and place them in the private hands of liti- his or her attorney with a check and leaves ground in promoting fair employment prac- gants and their lawyers. Once such cases are it to the plaintiff and the attorney to divide tices. NAM's involvement in this area goes settled with the payment of money, they back to the 1960s when it was instrumental the proceeds. The Act as amended prohibits will be dismissed and the facts surrounding in promoting Plans for Progress, the fore- the "waiver" of attorney's fees as a condi- the allegedly discriminatory behavior of the tion of the settlement. This provision will runner of our affirmative action policies. And its efforts continued through the 1980s employer will be effectively buried. (It is likely create tremendous uncertainty re- when NAM took the lead in establishing the standard practic in most cases for employers garding appropriate attorney's fees at a consensus which preserved the policy of af- to insist upon confidentiality provisions in stage in the proceeding when both parties firmative action as a viable component of settlement agreements). Although the pri- are earnestly seeking to conclude litigation. our nation's employment structure. SHRM's vate litigant and his or her lawyer may be It is foreseeable that although the parties efforts in this area are as equally long- better off after the case has been settled, in a particular action may agree upon the standing. SHRM played a vital role in train- there is absolutely no guarantee that the amount of money the defendant should pay ing the human resources profession to un- employer will not continue discriminating the plaintiff in settlement of his or her legal derstand and implement the concepts of against other employees who were not party claims, the parties may be thousands of dol- equal employment opportunity in the work- to the litigation. lars apart with respect to the amount of at- place when the laws were first passed. In Punitive and compensatory, damages are torney's fees the plaintiff's attorney should the 1980s SHRM's activities included the also available for violations of California's receive. Disagreements between the parties preparation and filing of an Amicus Curiae (and their lawyers) about this issue will in- primary antidiscrimination law, the Fair brief before the Supreme Court in the land- evitably end up before a federal judge who Employment and Housing Act ("FEHA"). mark affirmative action case of Johnson V. will have to decide, among other things, the Commodore Home Sys., Inc. V. Superior Santa Clara County, California, arguing reasonableness of the fees after reviewing in Court, 32 Cal. 3d 211, 649 P.2d 912 (1982). that affirmative action was a necessary part detail all the time the plaintiff's attorney Unfortunately this has resulted in our of our employment system. SHRM's brief, has put into the case and his or her relative which I prepared, was cited by Justice Bren- standard practice under the FEHA for experience in the area. This provision will nan as providing the professional justifica- plaintiffs' attorneys to request a right-to- likely create rancor between the attorneys, tion for affirmative action. Thus, these two sue letter and commence a civil action long just as the parties have come to an under- leading organizations bring a long and in- before the Department of Fair Employment standing as to the value of the case. There volved background to the current debate and Housing has had a chance to investi- do not appear to be any overriding public over our equal employment policies. gate, conciliate and/or seek redress of policy reasons for encouraging attorneys to The Civil Rights Act of 1990 represents a claimed discrimination. Similarly; under the have more of a monetary stake in the out- massive restructuring and rewriting of our Act as amended, plaintiffs' attorneys, driven come of these cases than they already have. equal employment laws. Presented as a re- by a contingent-fee arrangement, will likely No evil exists which this Section is needed sponse to certain Supreme Court decisions seek to by-pass the EEOC entirely and com- to correct. of last term, the draft legislation in fact re- mence litigation in the federal courts. The I appreciate the opportunity to testify jects the concept of conciliation and rapid focus will shift from the remedy of employ- before the committee and I would be settlement of complaints, which the Con- ment discrimination process, which Title pleased to answer any questions you may gress used as its guidepost in 1964 when have. VII was enacted to accomplish, to a process Title VII was enacted, and assumes that the which creates higher litigation stakes fueled only resolution of discrimination complaints TESTIMONY ON BEHALF OF NATIONAL ASSOCIA- by large dollar contingent fee awards. An is in protracted litigation in a federal court TION OF MANUFACTURERS AND SOCIETY FOR additional likely result will be a sharp in- system which is already overburdened. We HUMAN RESOURCE MANAGEMENT, BEFORE crease in federal court jury trial litigation find this thrust particularly ill-conceived at THE COMMITTEE ON LABOR AND HUMAN RE- which will further burden the federal court a time when there is almost universal recog- SOURCES, FEBRUARY 27, 1990 system. nition that the problem our economy faces Mr. Chairman, members of the Commit- in the 1990s is not too few jobs but too few Further, the proposed amendment to Sec- tee, my name is Lawrence Lorber. I am a tion 706(g) of the Act contains no defini- trained or trainable employees. A congres- partner in the law firm of Kelley Drye & sional commitment of scarce federal re- tions for a jury to look to in deciding wheth- Warren. I am submitting this testimony on sources to increased federal court litigation er to award punitive damages against an em- behalf of the National Association of Manu- seems particularly ill-advised when our ployer. The lack of a clear definition as well facturers ("NAM") and the Society for country faces such pressing employment as the relatively low standard of proof (pre- Human Resource Management ("SHRM") problems. In the recent annual economic ponderance of the evidence as contrasted (formerly the American Society for Person- report issued by the President, the employ- with "clear and convincing evidence" in nel Administration). ment concerns of America were identified as California) will leave an employer without The National Association of Manufactur- the necessity to find skilled workers for the an understanding of the kind of conduct it ers is a voluntary business association of available jobs. The President's Report, should avoid in order not to be punished by more than 13,500 member companies and which follows upon the Workforce 2000 an award of punitive damages. subsidiaries, large and small, located in study issued by the Department of Labor Additional problems created by Section 8 every state. Members range in size from the and the many private studies focusing on of the Bill arise from the fact that it would very large to the more than 9,000 smaller the employee shortage we are facing identi- impose compensatory damages and punitive manufacturing firms, each with fewer than fies the trained labor shortage as a grave damages on top of an existing remedial 500 employees. NAM member companies problem of national proportions. scheme which already grants to successful employ 85 percent of all workers in manu- Our country has long since outgrown the plaintiffs the right to recover lost wages, facturing and produce more than 80 percent pernicious "luxury" of discriminatory exclu- back pay and reinstatement or front pay. of the nation's manufactured goods. NAM is sion. In the increasingly tight labor markets Since the issues of Title VII violation and of the 1990s, employers inclined to indulge reinstatement or front pay (where reinstate- in discriminatory hiring will pay a high "This problem has been resolved by some of the ment is not feasible) are issues for the price for it-they will be unable to meet circuits which have addressed it in the context of court-not the jury-while compensatory combined Title VII and Section 1981 actions. They their own need for workers. The protected and punitive damage claims are jury ques- generally hold that the jury's factual determina- groups-minorities and women-will com- tions, a serious and complex issue involving tions on the Section 1981 claims control. See, ea, prise the overwhelming percentage of new judicial economy arises. The act provides Sherman D. Burke Contracting Inc., 891 F.2d 1527 entrants to the workforce. Employers who (11th Cir. 1990); Wade a Orange County, 844 F.2d are unwilling to hire them for reasons of absolutely no guidance as to how to avoid 951 (2d Cir. 1988). bias will find themselves increasingly unable March 26, 1990 CONGRESSIONAL RECORD SENATE 3159 to find qualified workers. Therefore; it is tice is predictive of Job performance, corre- ironic that at a. time when business necessi- ly unmanageable, as would be the burden lates to important elements of work behav- ty dictates open,nondiscriminatory:employ when reviewing the multistage hiring proc- lior, or more generally relates to the specific ess for management trainees, first line su- ment practices, Congress is seeking to place job functions in question. The proposed new greater rigidities on the labor market. We pervisors, public law enforcement positions definition of business necessity, would over- think this would be counterproductive to turn these long-standing precedents and or other such positions. The very complex- expanded workforce opportunities. This leg- impose an impossible burden on employers. ity of the employer's burden when dealing islation. however, ignores these pressing Understanding that the legal review of with aggregated, subjective employment problems and focuses single-mindedly on employment practices does not even begin practices would require decisionmaking narrow and technical litigation concerns of until there is proof of a numerical imbal- aimed at numerical balance, rather than interest primarily to lawyers. ance defined as adverse impact under the business judgment, in order to avoid the The Civil Rights Act of 1990 does not pro- proposed legislation, employers would have crushing costs which would be required to fess to create jobs or provide skills. It does, to show that the suspect practice, or the even attempt to defend challenged criteria. however, promise to vastly increase conten- "overall employment process" (see new defi- In Watson and Wards Cove, the Supreme tious litigation. Beginning with the several nition "n") are not only necessary but are Court attempted to craft a rational balance new definitions to Title VII, the legislation "essential". The judgment as to what is "es- allowing long-accepted Title VII obligations, places employers in a position where they sential" would not be made by the employer and heretofore unquestioned general litiga- have no reasonable opportunity to offer but by a Judge or possibly a jury, and then tion burdens to coexist with viable produc- nondiscrimiatory explanations to chal- in the context of a numerical deficiency tive employment systems. Proposed subsec- lenged employment practices. Put into this rather than actual business needs. The tion 703(k) and the new "definitions" would position, employers will have little choice promise of the Congress in 1964, as enunci- overturn this balance, while leaving employ- other than to assure numerical balance in ated in Griggs, that employers could estab- ers essentially defenseless to challenges of their workforce lish their own employment standards so subjective practices based on adverse impact DEFINITIONS long as the standards were consistent with analysis. Proposed new definition "n" includes the the employer's own business requirements SECTION 5 term "group of employment practices" and equal employment principles will thus Proposed Section 5 of the draft legislation within the scope of Title VII. This defini- be consigned to a footnote describing dis- would "deal" with the Price Waterhouse tion, as applied to both disparate treatment carded policy. Rather, the law would require case by amending Title VII to find a viola- and adverse impact cases, would place the employers to accept bare minimum qualifi- tion whenever a discriminating factor was entire range of an employer's employment cations or performance levels since they shown to have been a "motivating factor" in practices under question without providing would be the only standards which could any personnel action regardless of the pres- an employer with any specificity as to which possibly meet the "essential" test. ence or importance of other factors support- practice is questionable. The legal inquiry SECTION 4 ing the action. Section 5 is here character- would be changed from an examination of a Proposed definition "n" discussed above, ized as "dealing" with Price Waterhouse single suspect practice into an open-ended would abolish the requirement that a plain- since at the time of the decision It was inquisition of an employer if its total work- tiff identify the cause of a statistical dispar- greeted as a major advance by civil rights force did not reflect some idealized numeri- ity. Proposed subsection 703(k) would also advocates and was said to represent the first cal balance suggested by a plaintiff. This overturn those parts of the Court's holdings time the Supreme Court had recognized the new defintion rejects long accepted Title in Watson and Wards Cove related to bur- well-established concept of mixed motives in VII jurisprudence. In Connecticut V. Teal, dens of proof. the title VII context. The drafters of section Justice Brennan analyzed the various ad- The Civil Rights Act of 1990 would permit 5 clearly intend to expand upon Price Wa- verse impact cases since Griggs and made a plaintiff's cause of action to be based terhouse by finding liability where a dis- clear that Title VII never required the focus solely on the statistical "bottom line". That criminatory consideration is a motivating to be placed on the overall number of mi- is, a plaintiff need not identify one specific factor as opposed to the motivating factor nority or female applicants hired or promot- employment practice causing an adverse or even a substantial motivating factor. ed. impact, but could complain generally about Indeed the mere presence in the mind of In Transit Authority V. Beazer, the Su- a group of practices or point to the overall the decisionmaker or in the employer's preme Court focused on a single identified "employment process" to establish the nu- records of any questionable consideration or employment practice. To permit a lawsuit to merical threshold necessary for a showing inartfully phrased concern about an individ- be based on a "group of employment prac- of adverse impact. An employer would then ual would, by the terms of the proposed tices"-perhaps all practices used by a par- have the burden of showing that some or all amendment, doom the employment deci- ticular employer and to have that lawsuit of its practices-depending upon the scope sion. The legislation would preclude an em- triggered because the "overall employment of the compliant-are not causally related ployer's ability to rebut or refute the Infer- practice" results in a workforce that is nu- to the numerical deficiency. The employer ence of discrimination by proving that the merically deficient-is a profound change in would then be obliged to prove that each of factor was irrelevant because of the pre- the standard for reviewing personnel prac- these practices is "essential" to its business. dominant weight of legitimate factors. tices. It will put pressure on employers to Thus, an employer using a variety of em- Once obvious result of this section. were it assure that their overall employment prac- ployment practices would have to first parse to become law. would be to require legal tices result in a workforce measured by arbi- all of its practices, identify which caused review of personnel appraisals, supervisory trary numerical standards, and not produc- the numerical "discrimination" and then ratings and similar personnel tools while in tivity or ability. prove that the suspect practice was "essen- draft stage in order to scrub or delete any Proposed new definition "0" would find tial" to Its business. phrase or reference which could be pointed "business necessity" justifying a selection Proving that some objective selection cri- to as a "motivating factor" and which would criterion only if that criterion were proven terion-such as a college degree-is "esssen- thereby subject an employer to absolute li- to be "essential to effective job perform- tial" to success on a job is difficult enough. ability. Employers would almost have to es- ance." This new definition is a drastic But in the context of subjective criteria the tablish legal "thought police" to measure change from the definitions first set forth task becomes impossible. completely unrec- each consideration of a supervisor against in Griggs V. Duke Power Company which ognized in the bill or the accompanying con- the ever-changing legal standards of inten- has become well settled law during the suc- gressional analysis is the fact that the tional discrimination in order to insulate ceeding nineteen years. Watson and Wards Cove cases dealt with the employment process. In Griggs the Supreme Court first enunci- non-standardized subjective practices not The argument by the proponents of Sec- ated the theory of adverse impact, and im- heretofore dealt with under the impact tion 5 that Price Waterhouse authorizes "a posed on employers the requirement of analysis. The proposed legislation is built on little bit of discrimination" Is specious. The showing that a challenged practice was jus- the faulty premise that every employment Supreme Court crafted an appropriate tified by "business necessity". The Court practice. including interviews, supervisory burden shift by requiring employers to do said that the standard of business necessity ratings and the like, can be reviewed with more than merely articulate an explanation meant "job relatedness", meaning a selec- scientifc precision. Unlike the accepted for the "taint." Employers were given a dif- tion criterion "having a manifest relation- methodology for establishing the job relat- ficult burden of proof to avoid liability. The ship to the employment in question." The edness of objective "pass-fail" instruments draft legislation "cures" Price Waterhouse Court in Griggs reemphasized congressional or practices such as standardized tests or by abolishing any opportunity for defense. intent to allow employers to set their em- height-weight standards, where business ne- Strangely, the draft legislation seeks to ployment standards as high as they wished cessity has never been converted into the amend § 706(g) by including the Price Wa- as long as the business necessity test was legal sine qua non which this legislation terhouse "defense" in that section. The met. The various Supreme Court and appel- would mandate, the prospect. of proving intent of this placement is unclear. Clearer late court rulings subsequent to Griggs have that it is "esstential" to job performance for drafting would have new $ 703(1) add at its made it clear that 'business necessity" re- a candidate to appear "bright" or "motivat- end "except that a respondent will not quires a showing that the challenged prac- ed" during an interview would be complete- commit an unlawful employment practice 3160 CONGRESSIONAL RECORD SENATE March 26, 1990 where it establishes that it would not have Court ruling which triggered this section. taken the same action notwithstanding the There seems to be no rationale for this four- would be effectively terminated, and the consideration of the prohibited factor. fold expansion of the statute of limitations; courts would be inundated with new em- nor does there appear to have been consid- ployment suits. SECTION 6 In Martin V. Wilks, a five justice majority eration of other, parallel changes sure to Nor is this a spectral parade of horrors of the Supreme Court held that where al- follow, such as the extension of EEOC's raised by employers with untold hidden li- legedly race conscious promotion decisions record retention rules to two years and ability. Rather, it reflects the experience in other administrative changes. The legisla- those states with expanding doctrines of were being made as a result of the operation tion is also silent as to the impact of this wrongful discharge and expanding liability of a prior consent decree, white individuals who were not party to the proceedings change on cases filed with deferral agencies, judgments. Employers would be ill-advised to undertake thoughtful self-analysis and which resulted in the entry of the decree The silence with respect to the status of de- could bring suit alleging that the denial of ferral states apparently will allow simulta- corrective action for fear of unleashing a promotions to them was due to impermissi- neous processing of charges and could torrent of two-year old "intentional discrim- ble considerations of race. The four dissent- create redundant legal actions in different ination" litigation with million dollar liabil- forums. This result would be a direct contra- ity claims. Short of resurrecting the plain- ers argued that obedience to the dictates of a lawfully entered consent decree should diction of Title VII's fundamental purpose tiff's bar, no cogent explanation has been given for this section. not expose an employer to collateral attack to foster conciliation and settlement of and potential liability. The Supreme Court cases. We would also note that the Senate debat- The drafters have apparently given no ed this Issue when it recently passed the was grappling with the competing and thought to the ramifications of this propos- Americans With Disabilities Act ("ADA"). equally compelling concepts of affording every individual his or her own day in court al on actual employment processes. It is dif- Following long negotiations between the White house and Senate, during which orga- with the-need to bring finality to litigation. ficult to imagine the benefit in allowing a Proposed section 6 would establish that a grievance to fester for at least two years nizations such as SHRM and NAM and the person could hot challenge the operation of before triggering the investigative and adju- disability community provided input, the a decree if the person were a party to the dicative processes of title VII. In that long Senate rejected the inclusion of compensa- interim, personnel will have changed, man- tory and punitive damages and jury trials proceeding, had notice that the proposed for the disabled as inappropriate in the em- judgment might affect his interests and was agers shifted, perhaps even ownership ployment title of the ADA. The Senate and given reasonable opportunity to object, or if changed, yet the employer will have to re- the Civil Rights community were correct a court determines that the objections being construct dated events in order to respond. Productive employment will be subject to then. We do not believe that those negotia- raised were raised by other persons during tions were undertaken in other than com- the pendency of the consideration of the forgotten land mines of forgotten actions plete good faith, yet we see a policy reversal decree when a charge is filed two or more years in a matter of months. Section 8 has no Section 6 would leave the adequacy of after the triggering occurrence. place in this legislation. notice to interested parties as the only Section 7(a)(2) reinstates the continuing grounds available to attack the lawful oper- violation theory by starting the running of SECTION 11 ation of a decree after it is entered. Appar- the statute of limitations only after a ques- This section would require all federal civil ently it would bring finality to issues even if tioned practice has adversely affected the rights laws to be "broadly construed," effec- the underlying decree incorporated race aggrieved party. Thus, the proposed legisla- tively providing that the actual statute conscious features and was of substantial tion has the effect of overturning United serve only as the starting point for judicial duration. While employers share the belief Airlines V. Evans decided in 1977, not 1987. review rather than providing textual limits that judicial oversight of employment poll- It is simply inappropriate policy to encour- on such review. This seems to be a needless cies not be open-ended and intrusive, we be- age potential plaintiffs to sit, on their rights invitation to judicial activism and could lieve that these concerns ought to be tem- for an extended period. There seems to be readily cause confusion. If the "broad con- pered somewhat in view of the appropriate no cogent reason for this other than to in- struction" were viewed by some to be limit ly strict standards for relief currently fol- crease employer exposure. ing rather than expanding, we would inevi- lowed by the courts in reviewing or impos- SECTION 8 tably have to respond to yet another round ing race conscious policies. The standards This section would amend Title VII to of congressional restoration. The Congress enunciated by the Supreme Court in John- provide for compensatory and punitive dam- should not invite such activism and thereby son V. Santa Clara County and Local 28 subject the law to transient determinations ages where intentional discrimination is Sheetmetal Workers V. EEOC ought to allay shown and, consistent with the principle of the meaning of "broad construction." concern that affirmative relief will unfairly that such damages fall under the definition Section 11(b) appears to abolish, in the hinder the expectations of nonparty individ- of "legal" rather than equitable relief, a context of civil rights, the doctrine that sub- uals or that a court will usurp the employ- jury trial would be provided sequent legislation that is more specific or er's human resources function. As much as any section of the proposed narrow in design operates to limit prior leg- We do believe that rather than rushing to legislation, this section would change the islation that is more expansive. If this is the simply "repeal" Martin V. Wilks, the Con- entire structure of our equal employment intent, section 11(b) ought to be thoroughly gress ought to take sufficient time to study laws. The issue of a jury trial and extraordi- debated. We see absolutely no reason legis- the issues and consider such possibilities as nary relief for discrimination was consid- latively fossilize every piece of civil rights statutory time limits for an employment ered by the drafters of the original Title VII legislation and simply add layer upon layer consent decree or specifying the scope of and rejected for a number of sound policy of "additional statutory language. Civil the fairnes hearing so that adequate notice reasons. Those reasons have not changed. rights and equal employment is not such a is in fact provided to all interested or poten- It was the considered view that discrimi- fragile concept so as to require this type of tially interested or impacted individuals. nation issues should be settled quickly, that legislative shield. As the organizations I am SECTION.7 the employee achieve make whole relief representing today showed in the debate In Lorance AT&T Technologies, the Su- promptly and that the process avoid inter- over affirmative action, exposure to such debate, whether in the executive branch or preme Court held that a challenge to a se- minable delay in crowded federal courts. niority system allegedly adopted for a dis- Further, there was concern that juries the legislative branch, or before the public, criminatory purpose must be raised at the will not shrivel the reach of our equal em- might be loath to find for minority or time the seniority system is adopted (within female plaintiffs. ployment policies. There is no place for Sec- Title VII's limitation period) rather than at Since 1964, Title VII has been interpreted tion 11 in the proposed legislation. the time the system has its discriminatory and enforced in a relatively efficient SECTION 12 impact. The Court reiterated its view that manner, enabling individuals to achieved Section 12 of the proposed legislation there was no viability to the "continuing relief. To the extent there has been criti- would overturn the Patterson decision. The violation" theory of discrimination in this cism, it was that the EEOC was inefficient Administration similarly has introduced leg- context. The dissenters argued that Con- in conciliating cases and that backlogs were islation to accomplish this purpose. Rather gress never intended absolute immunity for permitted to expand. than legislatively "correct" an admittedly tainted seniority systems and that the deci- Section 8 would not respond to these con- strained judicial interpretation, the Con- sion would foster anticipatory litigation. cerns but would create new problems of gress ought to meet its responsibility by While the holding in Lorance is relatively vastly increased magnitude. Were this sec- thoroughly examining the ramifications and straightforward and deserving of careful tion enacted, any hope of conciliation and underlying rationale of the Supreme consideration, the legislative response incor- settlement through the EEOC would Court's action. porated in section 7 is wholly out of propor- vanish. We would witness instead a national The Patterson case involved alleged racial tion to the holding in Lorance and affects employment law lottery where attorneys harassment. Title VII makes racial harass- significant expansion of Title VII. would hold out to individuals the promise of ment illegal. The Supreme Court did not en- Section 7(a)(1) expands the statute of lim- six or seven figure judgments, with the ac- dorse racial harassment. It noted that the itations of Title VII from 180 days to two companying six or seven figure legal fee. remedial provisions of Title VII could have years. There was no "adverse" Supreme The purpose and function of the EEOC been available to the plaintiff. Rather, the March 26, 1990 CONGRESSIONAL RECORD - SENATE 3161 Court questioned, perhaps awkwardly, the ELECTIONS IN TAIWAN: A efficacy of having multiple statutory forms ing: control of the television and radio, MOMENT OF TRIUMPH FOR available to remedy discriminatory activities vast financial resources, a cooperative THE TAIWANESE and attempted by its decision to channel police and judiciary, as well as consid- such matters through the congressionally- Mr. PELL Mr. President, Eastern erable informal influence over the created scheme of Title VII. The underlying Europe, Central and Latin America most influential economic, social and question which the Supreme Court attempt- are not the only places in the world cultural organizations. ed. to resolve was whether it. made sound where democracy is emerging from the Importantly, the issue of Taiwan's policy. to have such multiple forums. The long, cold winter of dictatorship. independence was also prominently Congress ought to take the time to examine In Taiwan, thousands of protestors, raised in this election despite legal whether it makes any sense to have such mainly students, have gathered in a prohibitions against such discussion. anomalous situations as litigations in which Taipei city park to declare their sup- This indicates both new flexibility on both Title VII and $1981 are at issue and in port for greater democracy just as Chi- the part of the Government as well as which the same facts are tried partly before nese students gathered last spring in the continued importance of this issue a judge and partly before a jury, either at Tiananmen Square. However, unlike in the same time or on alternate days, in to the Taiwanese people. Twenty DPP China, rather than being brutually which different procedural rules and stat- candidates in favor of independence utes of limitations would apply and differ- suppressed, their voices have real hope won election, seven of these to parlia- ent remedies would be available. We believe of being heard ment. that the Congress ought to examine wheth We need to support the Taiwanese However, the elections in December er plaintiffs ought to be required to choose people in their courageous call for and March also illuminate continued an exclusive forum, and whether equal em- greater freedom and independence problems in the Taiwanese political ployment litigation ought not be encum- from the stultifying oppression of 40 system. In the Legislative Yuan èlec- bered with parallel federal, state and years of Kuomintang rule. tions, for example, only 101 out of 292 common law counts We would urge that We can take some encouragement were contested. The majority of 162 considered legislative attention be devoted from the actions taken by President continue to be filled with holdovers to examining and addressing and underlying Lee Teng-hui, a native Taiwanese, who from the mainland and 29 were ap- causes of the Supreme Court's decision has just been elected to a 6-year term, rather than rushing to "reverse" the at- pointed by the KMT to represent despite an effort by hardliners in the tempt of the Supreme Court to bring reason overseas Chinese. The President was Nationalist Party to replace him. to an unnecessarily confused and cumber- elected by a 752 member National As- Having already taken determined some situation. sembly controlled by 668 KMT dele- action in the past toward democracy, gates, also holdovers from 1949. The CONCLUSION President Lee will surely heed the call voice of the Taiwanese people is still a Contrary to the representations of its co- for greater reform at a faster pace. In minority voice in their homeland. sponsors, the Civil Rights Act of 1990 far this spirit, I commend and congratu- But the winds of change can be felt exceeds its professed aim of "simply' revers- late him for this leadership. Ing certain Supreme ? Court decisions. this spring. Following the December Last December President Lee presid- Rather, the draft legislation will effect a ed over the first officially contested Telections, President Lee promised sea-change in the treatment of equal em- elections since 1949. At that time elec- more democratic reforms stating that ployment complaints, converting every tions were held for 101 seats in the na- the vote "indicate[d] the various charge into a federal court action; making tional legislature, the Legislative reform measures undertaken by the the administrative process of mediation and Yuan, 16 county executive positions Government in recent years had failed conciliation an unused and forgótten option and building up a backlog of cases calling on called magistrates, several city mayors, to meet the public's expectations. and seats on two city councils and the President Lee has met with the dem- scarce federal court resources Taiwan Provincial Assembly The re- onstrators in Talpei's Chiang K'ai- The draft legislation also reverses the long settled concept underlying Title VII sults sent a clear signal that the Tai- shek Memorial Park-a clear indica when it was passed and incorporated in the wanese people want change tion of his desire to accommodate new Griggs decision, of letting an employer set As noted the Deputy Secretary Gen- political voices. He has also proposed a its standards as high as it wishes. The legis. eral of the opposition Democratic Pro- meeting with the DPP and other lation would present American industry gressive Party, Tsai Shih-yuan, "it was groups in a national convention to dis- with the choice of bolling its legitimate em- a big victory for the opposition!" cus Taiwan's problems. ployment criteria down to the very few es- The Democratic Progressive Party This is clear evidence that change is sential elements which would result in a [DPP] won 38 percent of the popular occurring in Taiwan minimally competent workforce or facing vote in city and county executive races I hope it will lead to substantial lengthy and expensive litigation leading to winning 6 out of 21, including the big- reform in several areas, including an extraordinary relief in which the statutory gest prize of all-the executive post in examination of possible constitutional deck is stacked overwhelmingly against it. Taipei county. The KMT received just changes that would further institu- The only other option left to employers is 53 percent of the vote rather than the tionalize and preserve democratic the distasteful one of insuring numerical projected 70 percent. In the Legisla- practices, guarantees for freedom of balance. Finally. the draft legislation ignores the tive Yuan, the DPP increased its mem- speech, elections for other members of current procedural and statutory impedi- bership from 11. to 21 seats, giving it the Legislative Yuan, loosening of visa ments to rapid and equitable resolution of enough members to introduce legisla- restrictions on overseas Taiwanese or employment complaints. Rather than exam- tion Taiwanese-Americans seeking to ining the continued viability of multiple These important victories were return to Taiwan, and a release of po- forums and multiple statutory bases for em- achieved despite tremendous odds— litical prisoners. ployment litigation the legislation merely the DPP has only 20,000 members and In particular, I hope that Shih perpetuates the current unwieldy and ineffi- the KMT's is estimated at 1 to 2.5 mil- Ming-Teh will be released. This prison- cient system. lion out of an electorate of about 12 er-of-conscience has been jailed for 25 The issues raised by the Civil Rights Act million-and large hurdles. years. He is Taiwan's Nelson Mandela. of 1990 deserve careful and thoughtful anal- The National Democratic Institute First arrested in 1962, he was jailed ysis. The apparent rush to pass a bill with a for International Affairs [NDI] in an until 1977. He was arrested again in minimum of debate and consideration is an unseemly and inappropriate way of treating excellent pre-election report, entitled January 1980 for his role in the forma- civil rights. We urge that this committee re- "A. Moment In Political Transition: tion of an opposition magazine and flect upon the issues raised in this testimo- The December 1989 Elections In demonstrations on behalf of democra- ny and join with America's employers in ad- Taiwan," observed that the "KMT re- cy and independence. He has been in dressing the pressing issues we all face in tains near total control of almost all jail ever since. His American wife, the 1990s and beyond political, social, economic and media Linda Arrigo, was deported by the Mr. HATCH. Thank you, Mr. Presi- institutions in Taiwan," ensuring "the Government. Amnesty for Shih Ming- dent. KMT numerous institutional advan- Teh would send a clear signal of the I yield the floor. tages in the current campaign, includ- Government's desire to bury the prob- # Attend listening ! statement of Arneiple -done Vonept 2 pho- - strorg support of curl Rights If discracy been a model. avil right not partion irrue. But- STATEMENT of PRINCIPLE3 (to modifificaredy's fill). mention A.D.A. (nothing Pappered see awak ago.) May the activity histof ortybe Fokewin affirmative Anty 3:20 5/9 MICHAER JACKSON "Yo creek." ON A.D.A. bill & 1:30 backs 2:00 Hisps 3:00 Catchall group Mont Tar - listening services w/ Gu Bights groups ask he Camp, Vogt get suited Me Cethgin And how is it shaping of Commission - 6 ofthem fehird porus. Welcome. Here today to Rone Civ. Right Commission, 50 state sps Committee meanter Praise and. Aobs nomined is flird POMS' commitment: LD( This is anniv. of announce. of Brown v2. Road of Elere. Thankug, Cavagos Aekanl. Karl Handicaped Andernen NOT THERE Staff director L> commitment to enfacing laws Chairman Art getcher looking forward Badership the (gettio) A.D.A. A Negative Vote On Affirmative Action BY SHELBY STEELE centuries of unrelieved oppression. And to these arguments other very obvious facts must be added. In America, many marginally compe- IN A FEW SHORT YEARS, WHEN MY TWO tent or flatly incompetent whites are hired ev- children will be applying to college, the affirma- ery day - some because their white skin suits tive-action policies by which most universities the conscious or unconscious racial preference offer black students some form of preferential of their employers. The white children of alumni treatment will present me with a dilemma. I am are often grandfathered into elite universities in a middle-class black, a college professor, far what can only be seen as a residual benefit of from wealthy, but also well removed from the historic white privilege. Worse, white incompe- kind of deprivation that would qualify my chil- tence is always an individual matter, but for dren for the label "disadvantaged." Both of blacks it is often confirmation of ugly stereo- them have endured racial insensitivity from types. Given that unfairness cuts both ways, whites. They have been called names, have doesn't it only balance the scales of history, America, to know that this country, howe suffered slights and have experienced first hand doesn't this repay, in a small way, the systemat- imperfectly, recognizes its past sins and wis the peculiar malevolence that racism brings out ic denial under which my children's grandfather to correct them. of people. Yet they have never experienced lived out his days? Yet good intentions can blind us to the effe racial discrimination, have never been stopped In theory, affirmative action certainly has all they generate when implemented. In our SOC by their race on any path they have chosen to the moral symmetry that fairness requires. It is affirmative action is, among other things follow. Still, their society now tells them that if reformist and corrective, even repentent and testament to white good will and to black pov they will only designate themselves as black on redemptive. And I would never sneer at these and in the midst of these heavy investments their college applications, they will probably do good intentions. Born in the late 1940's in Chi- effects can be hard to see. But after 20 year better in the college lottery than if they conceal cago, I started my education (a charitable term, implementation I think that affirmative ac this fact. I think there is something of a Faust- in this case) in a segregated school, and suf- has shown itself to be more bad than good ian bargain in this. fered all the indignities that come to blacks in a that blacks - whom I will focus on in this es Of course many blacks and a considerable segregated society. My father, born in the South, - now stand to lose more from it than they g number of whites would say that I was sancti- made it only to the third grade before the white In talking with affirmative-action admi moniously making affirmative action into a test man's fields took permanent priority over his trators and with blacks and whites in gener: of character. They would say that this small formal education. And though he educated him- found that supporters of affirmative act preference is the meagerest recompense for self into an advanced reader with an almost focus on its good intentions and detract professorial authority, he could only drive a emphasize its negative effects. It was virtu: Shelby Steele is an English professor at San truck for a living, and never earned more than impossible to find people outside either cal Jose State University in California. A collection $90 a week in his entire life. So yes, it is crucial The closest I came was a white male mana of his essays, "The Content of Our Character," to my sense of citizenship, to my ability to at a large computer company who said, will be published in August. identify with the spirit and the interests of think it amounts to reverse discrimination, 46 Photo Copy Preservation I'll put up with a little of that for a little more diversity." But this only makes him a half- hearted supporter of affirmative action. I Affirmative action, the author think many people who don't really like affir- mative action support it to one degree or an- other anyway. I believe they do this because of what hap- pened to white and black Americans in the crucible of the 1960's, when whites were con- believes, has proved more bad than fronted with their racial guilt and blacks tast- ed their first real power. In that stormy time white absolution and black power coalesced into virtual mandates for society. Affirmative action became a meeting ground for those good. Blacks, he says, now stand to mandates in the law. At first, this meant insur- ing equal opportunity. The 1964 civil-rights bill was passed on the understanding that equal opportunity would not mean racial preference. But in the late 60's and early 70's, affirmative action underwent a remarkable escalation of lose more from it than they gain. its mission from simple anti-discrimination enforcement to social engineering by means of THE NEW YORK TIMES MAGAZINE / MAY 13, Photo Copy Preservation quotas, goals, timetables, set-asides discrimination explained racial im- and other forms of preferential which came to a head in the very late balances, it became easy to justify ing of racial discrimination. By m treatment. 60's, could no longer be satisfied by group remedies to presumed dis- ing black the color of prefere Legally, this was achieved through anything less than racial prefer- crimination rather than the normal these mandates have reburdened ences. I don't think these mandates, a series of executive orders and case-by-case redress. ciety with the very marriage of CI in themselves, were wrong, because Equal Employment Opportunity Co- Even though blacks had made and preference (in reverse) that mission guidelines that allowed ra- whites clearly needed to do better by set out to eradicate. great advances during the 60's with- blacks and blacks needed more real cial imbalances in the workplace to out quotas, the white mandate to When affirmative action grew power in society. But as they came stand as proof of racial discrimina- achieve a new racial innocence and social engineering, diversity beca together in affirmative action, their tion. Once it could be assumed that the black mandate to gain power, a golden word. Diversity is a te effect was to distort our understand- that applies democratic principle races and cultures rather than to zens, despite the fact that there nothing to indicate that real diver is the same thing as proportionate resentation. Too often the result of 1 on campuses for example, has be Nobody democracy of colors rather than people, an artificial diversity that g the appearance of an educational p ty between black and white stude that has not yet been achieved in re ty. Here again, racial preferences has the Carlton low society to leapfrog over the di cult problem of developing black: parity with whites and into a cosm diversity that covers the blemish disparity - a full six years after Combination. mission, only 26 to 28 percent of bla graduate from college. Racial representation is not same thing as racial developm Representation can be manu tured; development is always h earned. But it is the music of in 1. cence and power that we hear in al SOFTPACK mative action that causes us to C. Carlton to it and to its distracting empha 2. on representation. The fact is 1 Lowest tar. after 20 years of racial preferen is the gap between median incomes Lowest LOWEST black and white families is grea The taste than it was in the 1970's. None of nicotine. that's right." is to say that blacks don't need I cies that insure our right to ec opportunity, but what we need m of is the development that will lei take advantage of society's effort include us. TAR 1 mg I think one of the most troub NICOTINE 0.1 mg effects of racial preferences blacks is a kind of demoralizat Under affirmative action, the qua Carlton PACK that earns us preferential treatm is an implied inferiority. Howe this inferiority is explained - an is easily enough explained by myriad deprivations that grew ou 1mg.tar our oppression - it is still inferior 0.1 mg. nic. There are explanations and t there is the fact. And the fact must borne by the individual as a condit apart from the explanation, ap even from the fact that others himself also bear this condition. integrated situations in which bla U.S. Gov't. Test Method confirms of all king soft packs: must compete with whites who n be better prepared, these expla tions may quickly wear thin and Carlton is lowest pose the individual to racial as wel personal self-doubt. (Of cou whites also feel doubt, but only I sonally, not racially.) What this means in practical ter is that when blacks deliver the selves into integrated situations t encounter a nasty little reflex whites, a mindless, atavistic rel that responds to the color black V King Size Soft Pack: mg. "tar", 0.1 mg. SURGEON GENERAL'S WARNING: Cigarette negative sterotypes, such as intell nicotine av. per cigarette by FIC method. tual ineptness. I think this reflex ( Smoke Contains Carbon Monoxide. barrasses most whites today : thus it is usually quickly repress On an equally atavistic level, The American Tobacco Co. 1990. 48 Photo Copy Preservation After 20 years of affirmative action, black and white incomes are farther apart. black will be aware of the re- flex his color triggers and will feel a stab of horror at seeing himself reflected in this way. He, too, will do a quick repres- sion, but a lifetime of such stabbings is what constitutes his inner realm of racial doubt. Even when the black sees no implication of inferiority in ra- cial preferences, he knows that whites do, so that - con- sciously or unconsciously - the result is virtually the same. The effect of preferen- tial treatment - the lowering of normal standards to in- crease black representation - puts blacks at war with an expanded realm of debilitating doubt, so that the doubt itself becomes an unrecognized pre- occupation that undermines their ability to perform, espe- cially in integrated situations. I believe another liability of affirmative action comes from the fact that it indirect- ly encourages blacks to ex- ploit their own past victim- ization. Like implied inferior- ity, victimization is what jus- tifies preference, so that to receive the benefits of prefer- ential treatment one must, to some extent, become invest- ed in the view of one's self as a victim. In this way, affir- mative action nurtures a vic- tim-focused identity in blacks Princess Hotels. and sends us the message that there is more power in our past suffering than in our Quite simply, the best places tostay present achievements. in the best nlaces tovisit. When power itself grows out of suffering, blacks are en- couraged to expand the bound- aries of what qualifies as ra- cial oppression, a situation that can lead us to paint our victimization in vivid colors THE Princess even as we receive the benefits of preference. The same cor- Bermuda porations and institutions that Because you prefer the best. give us preference are also seen as our oppressors. At Stanford University, minority- group students - who receive For reservations and information, contact your travel agent or call 800-223-1818; in Canada 416-964-6641 at least the same financial aid as whites with the same need Acapulco: Acapulco Princess, Pierre Marques; Arizona: Scottsdale Princess; Bahamas: Bahamas Princess Resort - recently took over the presi- Casino; Bermuda: Southampton Princess, The Princess; California: Palm Springs Marquis Hotel and Villas dent's office demanding, Represented by Princess Hotels International, In among other things, more fi- nancial aid. But I think one of the worst prices that blacks pay for pref- (Continued on Page 73) THE NEW YORK TIMES MAGAZINE / MAY Photo Copy Preservation BLACKS Continued from Page 49 erence has to do with an illu- firmative action marks sion. I saw this illusion at work blacks with. In this sense, recently in the mother of a preferences make scape- middle-class black student goats of the very people they who was going off to his first seek to help. And it may be semester of college: "They that at a certain level em- owe us this, so don't think for a ployers impose a glass ceil- minute that you don't belong ing, but this may not be there." This is the logic by against the race so much as which many blacks, and some against the race's reputation WASHINGTON whites, justify affirmative ac- for having advanced by color tion - it is something "owed," as much as by competence. WEEK a form of reparation. But this This ceiling is the point at logic overlooks a much harder which corporations shift the IN REVIEW: and less digestible reality, that emphasis from color to com- it is impossible to repay blacks petency and stop playing the living today for the historic affirmative-action game. Exploring suffering of the race. If all Here preference backfires the issues blacks were given a million for blacks and becomes a dollars tomorrow it would not taint that holds them back. Of thatshape amount to a dime on the dollar course one could argue that our times for three centuries of oppres- this taint, which is after all in sion, nor would it dissolve the the minds of whites, becomes residues of that oppression nothing more than an excuse that we still carry today. The Each week, noted to discriminate against concept of historic reparation blacks. And certainly the re- journalists analyze grows out of man's need to sult is the same in either case the events that affect impose on the world'a degree - blacks don't get past the of justice that simply does not glass ceiling. But this argu- our lives on exist. Suffering can be endured ment does not get around the "Washington Week in and overcome, it cannot be re- fact that racial preferences paid, To think otherwise is to now taint this color with a Review," public televi- prolong the suffering. new theme of suspicion that sion's longest-running Several blacks I spoke with makes blacks even more vul- said they were still in favor of nerable to discrimination. In public affairs affirmative action because of this crucial yet gray area of program. the "subtle" discrimination perceived competence, prefer- Now in its 23rd blacks were subject to once ences make whites look better they were on the job. One pho- than they are and blacks year, "Washington tojournalist said, "They have worse, while doing nothing Week in Review" ways of ignoring you." A whatever to stop the very real black female television pro- discrimination that blacks provides a probing ducer said: "You can't file a may encounter. I don't wish to in-depth look at what lawsuit when your boss does- justify the glass ceiling here, n't invite you to the insider but only suggest the very sub- is happening in the meetings without ruining tle ways that affirmative ac- nation and the world. your career. So we still need tion revives rather than extin- affirmative action." Others Ford Motor guishes the old rationaliza- mentioned the infamous tions for racial discrimination. Company, in its 11th "glass ceiling" through which I believe affirmative action blacks can see the top posi- is problematic in our society consecutive year, is tions of authority but never because we have demanded proudly joined by reach them. But I don't think that it create parity between Ford Aerospace in racial preferences are a pro- the races rather than insure tection against this subtle dis- equal opportunity. Preferen- underwriting this crimination; I think they con- tial treatment does not teach informative program. tribute to it. skills, or educate, or instill mo- In any workplace, racial tivation. It only passes out en- "Washington Week preferences will always create titlement by color, a situation in Review" is pro- two-tiered populations com- that in my profession has cre- posed of preferreds and unpre- ated an unrealistically high de- duced by WETA in ferred. In the case of blacks mand for black professors. Washington, D.C. and whites, for instance, racial The social engineer's assump- preferences imply that whites Consult your local tion is that this high demand are superior just as they imply will inspire more blacks to listings for day that blacks are inferior. They earn Ph.D's and join the pro- and time in your not only reinforce America's fession. In fact, the number of oldest racial myth but, for blacks earning Ph.D's has de- community. blacks, they have the effect of clined in recent years. Ph.D's stigmatizing the already stig- must be developed from pre- matized. school on. They require family I think that much of the and community support. They "subtle" discrimination that must acquire an entire system blacks talk about is often (not of values that enables them to Ford always) discrimination work hard while delaying grat- against the stigma of ques- ification. tionable competence that af- It now seems clear that the 73 -5- heart ache. This is a very personal and sensitive area, and it should always remain a matter of individual choice, but I do think we have to have better methods of letting people know that families can be planned if they are desirous of having such information. 11. DO YOU FAVOR LEGALIZING ABORTION? This is a complicated area. I do not favor a federal abortion law. It seems to me that this is a matter for the individual states to decide. I, personally, feel that women should have the freedom to choose or not choose abortion and that it should always be done by competent medical personnel. 12. WHAT IS YOUR POSITION ON CHANGING THE SENIORITY SYSTEM OF CONGRESS? Chairmen of committees should be elected by their peers just as the Congressional leadership is selected. This change would make the committees more responsive to the needs of the people. It will not remove the chairmanships from the effective chairmen. Specifically, I propose that chairmen be elected by the committee members from the five most senior members of the committee. If the present chairman is effective, he will continue to serve as the chairman of the committee. 13. WHAT DO YOU CONSIDER TO BE THE NATIONAL PRIORITIES FOR THE NEXT CONGRESS? The priorities with which Congress must deal are to reach a just and secure peace, return stability to our economy, find a lasting solution to our rampant crime problems, deal with the preservation of our environment, and seek new ways to upgrade quality of life for all of our people and thus preserve and develop our human resources. 14. WHAT DO YOU CONSIDER TO BE THE RESPONSIBILITIES OF THE UNITED STATES AS A MAJOR WORLD POWER? The role of the United States as a major world power carries with it awesome responsibilities. It does not include being policeman for the world. But it does entail the maintenance of strength, economic and social as well as military, and a determination to live up to our existing commitments for our own security and the security of the free world. But we cannot allow ourselves to be dragged into conflicts around the world when we have no interest involved. We now know that money will not buy the good will of our world neighbors, nor will increasing world trade in war weapons insure peace. Our main responsi- bility is to be so secure internally, that by our example, there can be no question that democracy is freedom and justice, and it works. 15. WHAT IS YOUR POSITION ON OPEN-HOUSING? In April of 1968 the Congress passed the Civil Rights Act of 1968 which included a section providing for fair housing. At that time, I expressed some concern about some of the provisions of the open-housing section. Although the individual homeowner was exempt when he sold directly to a buyer, I felt he should have the right to -6- sell or rent through a real estate agent. The way the bill was written, however, it was discriminatory toward the real estate agent. I voted for this bill because I did not feel that in all good conscience and fairness I could vote against legislation which would permit a Negro to buy or rent a home of his choosing if he has the money. I put great emphasis in voting for that bill on the anti-riot provisions of the bill, and I think it is significant that the "Chicago Seven" were convicted under this law. I recognized and fought against the imperfections of this bill, but finally voted for it because we must have strong law enforcement and we must, while protecting individual property rights, offer hope and fair play to all Americans regardless of their color. 16. WHAT IS YOUR STAND ON THE ANTI-BALLISTIC MISSLE (ABM) SAFEGUARD SYSTEM? I am convinced that the initial deployment steps of the ABM have been helpful in getting the SALT talks under way. I supported the initial deployment requested last year and the limited - one additional base - increase this year. I would like to see the SALT talks so successful and with such inspection safeguards that the full deploy- ment of ABM will not be necessary. 17. WHAT CAUSES INFLATION? HOW DO YOU FEEL IT COULD BE STOPPED? Inflation is caused for the most part by excessive, wasteful government spending and fiscal irresponsibility on the part of labor and business in setting wage and price policies. A curb on wasteful spending by government and restraint by business and labor will be required to stop inflation. During the period from 1960-1968, the federal government spent $60.2 billion more than it took in. This is what has caused the tremendous inflation we have been suffering from. This is what must be stopped. President Nixon has submitted a budget that will permit a surplus, but the Democrat Congress again seems deter- mined to create another deficit. I am working to keep this government spending within the bounds of fiscal responsibility, effectiveness, and efficiency. 18. DO YOU APPROVE OF GIVING FOREIGN AID TO COMMUNIST OR PRO- COMMUNIST COUNTRIES? No. I have voted in the House against doing this. 19. WHAT IS YOUR ATTITUDE TOWARD THOSE WHO PROTEST THE WAR IN VIETNAM? Lawful protests are a fundamental right we must protect. Unlaw- ful protests subvert our society and must not be condoned. 20. HOW DO YOU FEEL ABOUT SEX EDUCATION IN THE SCHOOLS? I think that what is needed is some kind of balance and good taste in handling sex education. Ideally, the school and the home should be able to work together to create a sound balance between scientific knowledge and morality. This is indeed a sensitive subject, and I Services of Mead Data Central PAGE 4 6TH STORY of Level 2 printed in FULL format. Copyright (c) 1990 The Washington Post January 28, 1990, Sunday, Final Edition SECTION: OUTLOOK; PAGE C1 LENGTH: 1520 words HEADLINE: Why Blacks Like Bush; He's Got the Image - But Soon He'll Need Results SERIES: Occasional BYLINE: Juan Williams BODY: AS GEORGE Bush stands before Congress this week to deliver his annual State of the Union message, his political power is made stronger by support from a suprising quarter: black Americans. Blacks are at the heart of the president's overall popularity, says Lee Atwater, chairman of the Republican National Committee. At this point in his presidency, Bush enjoys the highest approval level of any post-World War II president. Atwater believes good feelings about Bush in the black community translate into higher approval ratings across the political spectrum. In fact, Bush has consistently scored high with black voters since taking office. Last February he had a 61 percent approval rating among blacks; that rating has now climbed to 74 percent -- only six points lower than among whites. Even Americans who are not employed, a disproportionate share of whom are black, give the president a 76 percent approval rating. Here is a paradox. George Bush served for eight years as vice president to Ronald Reagan, the most unpopular president with blacks in modern history. He ran his successful presidential campaign using the face of Willie Horton - the black rapist and slasher - as a frightening logo and drew only about 12 percent of the black vote. Yet now he is almost as popular with the black public as with the white. How can this be? One explanation, offered by Milton Morris, research director for the Joint Center for Political Studies, the nation's major black think tank, is that most black Americans, like most white Americans, like to like their president. Says Morris, "The black community was dying to express support for someone in the White House and George Bush is the lucky ben eficiary of that desire. And to his credit he has been accessible and willing to be responsive to black issues and concerns." Atwater doubts that blacks perceived Bush's Willie Horton ads as racist. "If black voters truly thought it was a racial campaign they wouldn't support him," says Atwater. "Black voters understand the furlough issue, the crime issue." As for Bush's position as Reagan's successor, it seems to have helped rather than hurt him: To a degree, Reagan's adversarial relationship with blacks was the launching pad for Bush's high ratings. "It has been 50 easy to stand out in sharp contrast to Ronald Reagan when it comes to black people," says Morris. LEXIS® NEXIS® LEXIS® NEXIS ® Services of Mead Data Central PAGE 5 (c) 1990 The Washington Post, January 28, 1990 But Bush has also taken positive steps to improve his standing with blacks. Most have involved more public relations than substance - meeting with national and foreign black leaders, speaking at the National Baptist Convention. But these visible acts of leadership have apparently been important in setting the tone for his administration. "There is no question in my mind that Ronald Reagan would not have met with Bishop Tutu - Bush did," says Benjamin Hooks, the NAACP director who met only once with Reagan but has had five meetings with Bush during his first year in office. "I have the impression," Hooks adds, "that Bush comes from the old-line, moderate wing of the Republican party like his father before him. He doesn't trace his political line to Barry Goldwater who turned Republicans away from black people." Unlike Reagan, Bush has not made himself an opponent of affirmative action. After the Supreme Court struck down a contract set-aside plan last year, Bush said he would "not read into that a mandate to me to stop trying on equal employment and on affirmative action generally." Bush is also praised for appointing blacks to high-level positions. His most visible choices have been Colin Powell, as chairman of the Joint Chiefs of Staff; Constance Newman as head of the Office of Personel Management; Fred McClure as head of congressional liaison ; and Louis Sullivan as head of the Health and Human Services Department. Although Powell was originally elevated to the influential position of National Security Adviser by Reagan, Bush has garnered far more credit for his appointments. "I'll tell you one key difference between Bush and Reagan's black appointees," says Armstrong Williams, vice-president of B&C Associates in Highpoint, N.C. and a former Reagan administration appointee. "Bush puts people there because they are qualified." Instead, Williams feels, Reagan's main interest was "statistics - so he could rattle off how many blacks worked for him." "No one who saw [Powell] during the Panama crisis was talking about affirmative action --- they were saying what a strong commander he is," says Williams, "and the man who put those people in place, who gave them responsibility and listens to them is George Bush. = Bush has also pursued a strategy of going beyond black leaders to visit black neighborhoods and homes. Last week he visited a Kansas City community, the week before he was at a public housing project in Alexandria. "He was comfortable and they were comfortable with him," says Jack Kemp, the housing secretary who accompanied Bush to the housing project. "They didn't come up and say I want to join the Republican party but they did say 'Keep it up Mr. President Don't give up on us.' And when he said to them he wants to do something to reverse 30 years of failed social policy by putting rewards back in life for cleaning up your house, staying in school, and taking jobs, those people are saying to him, 'Yes, sir, we'd be proud to be a part of something that stands for dignity, justice and pride.' LEXIS® ® NEXIS® ® LEXIS® NEXIS® Services of Mead Data Central PAGE 7 (c) 1990 The Washington Post, January 28, 1990 "It will not last," says Michael Frazier, legislative aide to Sen. Edward Kennedy (D-Mass.). Pointing to pending measures dealing with discrimination in the workplace, the death penalty and South Africa, Frazier predicts that "Bush will have to take stands on issues of importance to black America in the next year. Let's see if he is still popular by the end of this year." GRAPHIC: ILLUSTRATION, PETER ALSBERG TYPE: FEATURE SUBJECT: BLACK; U.S. PRESIDENT NAMED-PERSONS: GEORGE BUSH LEXIS® ® NEXIS® ® LEXIS® NEXIS ® George Bush for GEORGE BUSH on APPIRMATIVE ACTION George Bush supports allitmative action. As .1 businessman in Texas, he practiced affirmative action in hiring and propotion of black and hispanic employees. The bene- ficial effects of affirmative action policies. can be seen in the closing gap in wage rates between white and black workers, particularly among the young and college-educated. However, he is opposed to quotas in Federal or other hiring. and for the Telefan tenm. an Washington DI 20201 CW: 11.29.1 AT `IRMATIVE ACTION QUESTION: DO YOU SUPPORT APPIRMATIVE ACTION? ANSWER: I support affirmative action, as it. helps bring people "P 10 the starting line on an equal fooling. But I have opposed quotas, SOURCE: JEWISH LIVING MAGAZINE OUESTIONNATRE from 3rd person. 1977, private citizen Goorge Bush served 88 host and "e sponsor of Howard University's "New Directions" raising drive. July, Candidate for President George Bush appointed Flotcher (author of the Affirmative Action Legislation 1974) as Chairman of Blacks for Bush. BUSH PACTS George Hush, more than any other candidate, has both the experience and the sensitivity to work in the interest of all the people of the United States. His convictions that minorities must be represented in responsible positions in all areas of government are firm Bush is equally committed to creating opportunity for minorities in the private sector, and these concerns will be of primary importance to his administration when he 1s elected to the Presidency. Specifically, in his numerous positions in private and public life, he has worked to insure the participation of minorities at every turn. - In the late 1950's he was Chairman or the Midland, Texas United Way Annual Campaign. - As President and co-founder of ZAPATA off-Shore Company, George Bush worked hard to train and hire Mexican-Americans and Blacks at. All levels of the corporation. - A Congressman from Houston, Texas from 1966-1970, Bush sponsored and fought for Civil Rights legislation, including the Fair Housing Act. - In 1970, George Bush became our Ambassador to the United Nations where greater than one-third of his staff was Black. In 1972, he appointed a Black, Arthur Feltcher (recently a candidate for Mayor in Washington, D.C.) to compaign nationwide in support of the United St.at.es., position on the crucial II 2 China = question. - In 1972, as Chairman of the Republican National Committee, Goorge Bush initiated 8 program to attract minoritics in large numbers 1.0 the Republican Party through increased voter education and registration drives. In those R.R.C. years he also started the National Black Republican Council and was the first Republican official at that high level to meet b1-weekly with members of the National Association of Black Press, - After 2 years as our Ambassador to China, Bush was brought back to this country t.o head the Central Intelligence Agency. There, lie was the first CIA Director to initiate a program to actively solicit and train minorities for responsible roles in the intelligence community and State Department. Torposident. for GEORGE BUSH ON THE ISSUES AFFIRMATIVE ACTION George Bush has long favored action designed to ensure that every American has equal access to opportunity, but he opposes quotas as arbitrary and unfair. The Bakke decision struck down earlier decisions favoring quotas. George Bush supports that decision. A copy of out report is "D file with the Federal Election Commission and available for purchase from the Federal Fixtion Commission Washington DC 20443 C030000 CIVIL RIGHTS/*RECORD In 1968, as a freshman congressman. Mr. Bush headed back to his conservative Republican district in Houston after casting a vote in favor of landmark open-housing legislation. "Somehow it seems fundamental that a man should not have a door slammed in his face because he is a Negro or speaks with a Latin American accent. " he said. -- The Sun, January 17, 1988. Bush is matter-of-fact in acknowledging that he was not out front on civil rights in the '60s. But he reacts strongly to any suggestion that his privileged upbringing might naturally make him insensitive to the needs of minorities and the poor. "Did they ask that of Franklin D. Roosevelt? or John Kennedy? The answer is no. They ask it of Republicans who came from backgrounds like mine. They don't ask it of Democrats. See, if I were a Democrat, nobody would think of asking me a question like that because I would be spending more (federal money) on whatever it is. -- Inquirer, February 28, 1988. "I voted for every piece of civil rights legislation for the four short years I was in Congress," Mr. Bush said in discussing the bill before the veto. "And I don't want to see us positioned - anything to interpret this as being against civil rights. -- New York Times, March 24, 1988. In April 1968, Rep. George Bush (R -Tex.) voted for a landmark fair housing bill Bush said, "I do not want it on my conscience that I have voted against legislation that would permit a Negro, say a Negro serviceman returning from Vietnam, where he has been fighting for the ideals of his country, to buy or rent a home of his choosing if he has the money.' "The place was jammed, he said. "Judging from the boos and catcalls when I was introduced, it was also seething. " Bush reminded them of the blacks fighting in Vietnam and asked how they would feel if a black veteran returned "only to be denied the freedom that we, as white Americans, enjoyed?" the crowd gave him a standing ovation, he recalled. -- The Washington Post, March 27, 1988. "I'm not going to start doing something 7-1/2 years into an administration that I haven't been willing to do before. Bush said at a news conference Thursday in Hartford, Conn., when asked if he supported the veto of the civil rights bill. "I'm not going to try now to distance myself. -- Philadelphia Inquirer, March 27, 1988. C030000 CIVIL RIGHTS/*GROVE CITY BILL Bush reiterated his position that the legislation as written was flawed and that he was not going and that he was not going to start contradicting Reagan this late in his term. but he said he supported the bill's underlying intent. Perhaps Rev. Jackson was talking when he should have been listening,' Bush said. It's not that I'm afraid to do what some of the Democrats are afraid to do go after him," Bush said. "But if he's the nominee, we'll have a chance to discuss civil rights records and I'll lay my record on the ground with anybody." -- (AP), March 25, 1988. "Don't use past pluperfect, let's go to the future, " he urged reporters when asked to clarify his position. "Others will try, the Democrats will try, they will try to get me to say would you have done this different from the president, you owe it to us to tell us. I'm going to say I don't think I do. I'll do it (Civil Rights) exactly the way I spelled out I'm going to do it. " -- The Washington Post, March 27, 1988. C030000 CIVIL RIGHTS/*GROVE CITY BILL The vice president said he favored the basic premise of the bill, but didn't want to go against the president on the matter. Besides, he said, the legislation was flawed. Jackson has scoffed at that, saying Bush lacks leadership. "Perhaps Rev. Jackson was talking when he should have been listening," Bush retorted Thursday. "If he's the nominee, we'll have a chance to discuss civil rights records and I'll lay my record on the ground with anybody." -- (AP), March 25, 1988. "I don't think anybody is going to be judged by one vote in one administration, Bush said when asked about criticism from Democratic presidential hopeful Jesse L. Jackson and others of his support of the veto, overridden by Congress this week. -- -Washington Post, March 25, 1988,. Sometimes we forget that civil rights isn't simply a bill, it's a whole state of mind in terms of education, a state of mind in terms of opportunity, a state of mind in terms of education, whatever these things are," Bush said. -- Washington Post, March 25, 1988. Bush emphasized that he was motivated by his policy of supporting positions taken by the president. Asked if he would oppose Reagan's veto, he said, "I'm not going to start doing that now, which I haven't done for seven and a half years.' -- Houston Chronicle, March 22, 1988. Bush said today that there were "shortcomings" in the bill, but when asked what his specific objections were, Bush offered only one, that the law might impinge on religious organizations and their operations such as day care centers. He did not elaborate. He indicated, however, that he did not have major objections. As for Jackson's criticism, Bush said: "Perhaps Rev. Jackson was talking when he should have been listening If he's the nominee we'll have a chance to talk about civil rights records. I'll lay mine on the ground with anybody." -- Washington Post, March 25, 1988. C030000 CIVIL RIGHTS/*GROVE CITY BILL Vice President George Bush indicated Monday he supported President Reagan's veto of a major civil rights bill, even as the House and Senate prepared to override the president's action. "Let me be very frank with you, " Bush told a group of his black supporters. "The legislation is imperfect, and the imperfections need to be corrected. Bush emphasized that he was motivated by his policy of supporting positions taken by the president. Asked if he would oppose Reagan's veto, he said, "I'm not going to start doing that now, which I haven't done for seven and half years. " -- Houston Chronicle, March 22, 1988. "I'm not going to start differing with the president after seven-and-a-half years into the vice presidency," "I've stood with the president, and that the legislation needs to be perfected, and I hope it will be.' -- The State, Columbia, South Carolina. Speaking to a black audience, Bush said the bill was "imperfect. The imperfections should be corrected." But then he went on to say he supported its purpose: "The Federal government must require that organizations that get tax dollars comply with our civil rights laws." -- (AP), March 23, 1988. "I'm not going to start doing that now which I hav'nt done in 7 1/2 years, " he told reporters. "I favor the overturning of Grove city. " -- Los Angeles Times, March 23, 1988. "I favor the overturning of Grove city." Bush said he believed the legislation passed by Congress was "imperfect" and could infringe on religious freedoms. -- Los Angeles Times, March 23, 1988. Vice President Bush said today that the civil rights bill Congress passed over President Reagan's veto this week should be "fully enforced," and though he continued to cite flaws in the measure he would not say whether he would have vetoed the bill himself. --- New York Times, March 24, 1988. C030000 CIVIL RIGHTS/*GROVE CITY BILL Bush adroitly maneuvered around the hard fact that earlier in the day, while campaigning in New Jersey, he had announced his support for President Reagan's veto last week of the Grove City civil rights bill passed by Congress. The bill broadly expands civil rights coverage for institutions receiving federal funds, and Reagan said he wants to "ensure equality" but that the bill is too intrusive. Bush said in his speech last night that he wasn't going to differ with Reagan on the matter, and he even drew a standing ovation by adding. "The federal government must require that organizations that get tax dollars comply with our civil rights laws. And that's fundamental. " -- Washington Post, March 22, 1988. Even so, he said of the so-called Grove City legislation: "The federal government must require that organizations that get tax dollars comply with our civil rights laws. And that is fundamental. Many in his audience stood to applaud this statement. Boston Globe, March 22, 1988. "Let me be very frank with you, Bush told a group of his black supporters. "The legislation is imperfect, and the imperfections should be corrected. " "Having said that, however, the federal government must require that organizations that get tax dollars comply with our civil rights laws. That's fundamental. " Bush told the gathering that civil rights "was not just a matter of social policy, but of fundamental right. " "If I am the Republican nominee," he continued, he continued, "I want to attract to this party -- the party of Lincoln -- the broadest base of Americans possible, and that includes blacks, Hispanics and all minorities." -- Houston Chronicle, March 22, 1988. "I've said I've stood with the President, and that the legislation needs to be perfected, and I hope it will be. " -- The Philadelphia Inquirer, March 22, 1988. "The pending legislation, let's face it, if we're rational with each other, is imperfect. The imperfections' should be corrected. "Having said that, " he added, "the federal government must require that organizations that get tax dollars comply with our civil rights laws. And that's fundamental. -- Washington Post, March 22, 1988. C030000 CIVIL RIGHTS/*GROVE CITY BILL Bush said he also supported President Reagan's veto of the Civil Rights Restoration Act passed both chambers earlier this year by large margins. Both supporters and opponents of the measure said there was little chance the veto would be sustained. It was prompted by a 1984 Supreme Court ruling that civil rights laws applied only to a specific program or activity receiving federal aid. Under the decision, for example, the government could not cut off money to a college if the discrimination occurred in a department that did not receive such aid. -- (AP), March 21, 1988. Asked if he would oppose Mr. Reagan's veto, he said, "I'm not going to start doing that now, which I haven't done for seven and half years. -- New York Times, March 22, 1988. "I'm not going to start doing that now which I haven't done in 7 1/2 years," "I favor the overturning of Grove City." Bush said he believed the legislation passed by Congress was "imperfect" and could infringe on religious freedoms. He told a group of local reporters in Connecticut that with selective veto power he could, as president, shape such a bill to his liking, vetoing those parts he does not like and signing the rest. -- Plain Dealer, March 22, 1988. "I'm not going to start differing with the president after 7 1/2 years into the vice presidency," Bush said Monday in Hartford, Conn. "I've said I've stood with the president, and that the legislation needs to be perfected, and I hope it will be." Bush said that while he considered the legislation "imperfect," he believes "The federal government must require that organizations that get tax dollars comply with our civil rights of every American." -- Orange County Register, March 22, 1988. Services of Mead Data Central PAGE 11 157TH STORY of Level 2 printed in FULL format. The Associated Press The materials in the AP file were compiled by The Associated Press. These materials may not be republished without the express written consent of The Associated Press. July 11, 1988, Monday, PM cycle SECTION: Washington Dateline LENGTH: 346 words HEADLINE: Don't Take Blacks for Granted, Hooks Tells Democrats DATELINE: WASHINGTON KEYWORD: NAACP BODY: Democrats should not take blacks for granted, and Republicans are making a mistake in ignoring the black vote, says NAACP Executive Director Benjamin L. Hooks. Hooks opened the 79th annual convention of the National Association for the Advancement of Colored People Sunday night with a speech in which he also called on blacks to emphasize self-help. "It would be a tragic mistake to take us for granted," Hooks said in remarks aimed at the Democrats. "Don't take us for granted." To the Republicans, he said, "You're making a terrible mistake to continue to ignore the black vote." Blacks have won an inspiring measure of economic, political and social freedom, Hooks said. But racism and hopelessness persist, he added. He accused the Reagan administration of abandoning the war on poverty and dismantling civil rights gains. "The question tonight I propose is: Where do we go from here?" Hooks said. In answering his own question, he said: "First of all, we shall go forward to first class citizenship only if we place renewed emphasis on self-help. What good is freedom of thought if you can't think? What good is freedom of speech if you can't speak?" Hooks praised Jesse Jackson's presidential campaign as "brilliant and incredible" but said the decision to seek or accept the vice presidency "is one that he alone has to make." About 16,000 people are expected to attend the five-day convention, whose theme is "Vote! Be Heard.' Vice President George Bush, the expected Republican presidential nominee, is scheduled to speak Tuesday and LEXIS® NEXIS® LEXIS® NEXIS ® Services of ead Data Central PAGE 12 The Associated Press, July 11, 1988 Massachusetts Gov. Michael Dukakis, the expected Democratic nominee, is to address the convention Wednesday. The 11-year-old grandson of Medgar Evers, the field secretary for the NAACP in Mississippi who was shot to death in 1963, spoke earlier Sunday in Arlington National Cemetery. "If we didn't have those like Malcolm x, Martin Luther King Jr. and Medgar Evers, we wouldn't be free today," said Daniel Evers Everette. "We wouldn't be able to go anywhere we want to. We wouldn't be able to do anything we want to." LEXIS® NEXIS® LEXIS® NEXIS® ® Services of Mead Data Central PAGE 13 150TH STORY of Level 2 printed in FULL format. The Associated Press The materials in the AP file were compiled by The Associated Press. These materials may not be republished without the express written consent of The Associated Press. July 12, 1988, Tuesday, AM cycle LENGTH: 625 words HEADLINE: Bush Pledges 'New Day' In Civil Rights If Elected President BYLINE: By TERENCE HUNT, AP White House Correspondent DATELINE: WASHINGTON KEYWORD: Bush BODY: Republican George Bush told blacks Tuesday his presidency would mark "a new day" after the Reagan administration, promising, "I will be personally involved in protecting the civil rights of all Americans." Appearing before the 79th convention of the NAACP, the vice president promised, "You will be heard, I promise you that. You're going to be called on. You're going to be partners in my presidency." Bush, sure to be the Republican presidential nominee, also paid tribute to Jesse Jackson, the runner-up in the Democratic presidential primaries. While saying he had profound policy differences with Jackson, Bush said, "I salute him for running the race, for being heard, and he deserves a salute from us." The audience of several thousand people applauded loudly, and generally gave Bush a warm response. Bush made no mention of the selection of Texas Sen. Lloyd Bentsen as the running mate of Michael Dukakis, the presumed Democratic presidential nominee. Later in the day, Bush planned to fly to Cincinnati to throw out the first pitch at baseball's All-Star Game. Republicans traditionally have not had much luck in attracting black voters. The Reagan administration has been criticized repeatedly by blacks, particularly for its record on civil rights and aid to the poor. Bush, however, has a relationship with many black leaders. In introducing Bush, NAACP executive director Benjamin Hooks praised the vice president's "long and distinguished record of public service" and called him a man "of honor and integrity." Using a baseball analogy, Bush told the NACCP that as a candidate for president, "I'm not just in the on-deck circle any more, I'm at the plate. And let me just say, it is a new day." LEXIS® NEXIS® LEXIS® NEXIS Services of Mead Data Central PAGE 14 The Associated Press, July 12, 1988 He promised that, "I will have a positive civil rights agenda. I guarantee you I will be personally involved in protecting the civil rights of all Americans. This effort will be at the top of the agenda of my attorney general, and he or she will be directly accountable to me for results." The audience respounded with applause and cheers. Bush said he did not intend to concede the vote of any American, but acknowledged it's tough for Republicans to win over blacks. "I need your help. I know I'll get your constructive criticism," he said, amid chuckles from the audience. "That's all right. You will be heard, I promise you that," Bush said. Bush said his commitment to include blacks was was not dependent on his receiving a certain percentage of the black vote. "I'm a realist. You all are realists," Bush said. "I'm going to do better than people think in that regard." He promised that " I will have minority men and women of excellence as full-scale partners in my administration. He said black leaders like Hooks "will always be welcome at my house, even when my house is your house - the White House." Bush credited the Reagan administration with "building a record of economic success" and said that a third of all black families now earn more than $25,000 a year. "But there's much more left to be done," Bush said. He said the government can be involved in dealing with problems such as pregnancy among unwed black teen-age girls and the high rate of black school dropouts. However, he added, "The answer also lies in the values that are passed on from generation to generation withington values like family, faith, education, the importance of work." "We must teach kids the difference between right and wrong. We must teach them how to say no to drugs and no to teen-age pregnancy. We must stop the cycle of babies having babies. And we must emphasize the importance of family and work and education." Bush promised that his first budget would seek a dramatic increase in funding for the Head Start program. LEXIS® NEXIS® LEXIS® NEXIS® Services of Mead Data Central PAGE 20 39TH STORY of Level 2 printed in FULL format. Copyright (c) 1989 Chicago Tribune Company; Chicago Tribune July 9, 1989, Sunday, CITY EDITION SECTION: NEWS; Pg. 6; ZONE: C LENGTH: 611 words HEADLINE: Bush will be better for blacks than Reagan, NAACP leader says BYLINE: From Chicago Tribune wires DATELINE: DETROIT BODY: George Bush will be a better president for black Americans than Ronald Reagan, whose administration ignored black leaders and let civil rights erode, NAACP leader Benjamin Hooks said. Hooks, speaking Friday before the group's annual convention, which opens Sunday, said Bush has shown a genuine desire to see the United States overcome its history of racism. "There's no question in my mind that Bush is going to be a better president than Reagan," Hooks said. "It would be hard to be a worse president than Reagan." The National Association for the Advancement of Colored People, the nation's oldest and largest civil rights group with 500, members, predicts 18,000 to 20,000 people will attend its 80th annual convention. "It's a sad fact that we're still about the same thing we were when we were founded in 1909 - eliminating all forms of racial discrimination," said Hooks, a former Federal Communications Commission member who became NAACP executive director in 1977. "Racism, sexism are alive and well," he said. Hooks said Bush, unlike Reagan, has been accessible to black leaders and has met with him and the Congressional Black Caucus, as well as with South African antiapartheid leaders Revs. Desmond Tutu and Allan Boesek, Hooks said he has known Bush for many years and considers him a member of the Republican Party's Eastern, more moderate wing. "He wants to do a good job, but he wants to be elected again," Hooks said. "There are various pressures working on him." Vice President Dan Quayle, 1988 Democratic presidential contender Jesse Jackson and U.S. Housing and Urban Development Secretary Jack Kemp are among those scheduled to address the NAACP convention, which runs through Thursday. Asked how delegates would receive Quayle, who would be making his first appearance before a black group, Hooks joked: "Oh, he'll get a reception. LEXIS® NEXIS® ® LEXIS® NEXIS® Services of Mead Data Central PAGE 21 (c) 1989 Chicago Tribune, July 9, 1989 Seriously, he'll get a cordial reception, I'm sure. If we didn't want to hear him, we wouldn't have invited him." A series of U.S. Supreme Court decisions narrowing federal civil rights laws and allowing white workers the right to counter-sue in affirmative action cases will be a hot convention topic, Hooks said. "The question on the minds of black folks around the country is how we deal with the recent spate of Supreme Court decisions that just emasculate the civil rights laws," he said. "In fact, it's going to get a lot worse before it gets better." = The Supreme Court has gone absolutely berserk. I can't believe that five people would be 50 dumb as the majority is in those cases," Hooks said. "It's either dumbness or out-and-out racism and sexism." In what is viewed by civil rights officials as the most significant ruling, the court on June 12 said white male employees can sue to reopen affirmative action court settlements if they feel they were subject to reverse discrimination. The ruling in Martin V. Wilks threatens to invalidate dozens of settlements involving police, firefighters and other public employees, legal scholars say. Hooks said the 80-year-old NAACP, which has 500,000 members, is exploring whether to push for passage of federal legislation dealing with affirmative action matters. A side effect of the Supreme Court's rulings has been interest in the NAACP among some people previously uninvolved. "I've seen young blacks in professional roles who haven't supported us sending checks and wanting to demonstrate," Hooks said. Other officials addressing the convention will be Democratic National Committee Chairman Ron Brown, Gov. James Blanchard, Mayor Coleman Young and United Auto Workers union President Owen Bieber. TERMS: UNITED STATES; OFFICIAL; BLACK; RIGHTS LEXIS® ® NEXIS® ® LEXIS® ® NEXIS ® Services of Mead Data Central PAGE 4 16TH STORY of Level 1 printed in FULL format. Copyright (c) 1989 Newsday, Inc. Newsday August 9, 1989, Wednesday, CITY EDITION SECTION: NEWS; Pg. 15 Other Edition: Nassau and Suffolk Pg. 5, Home Pg. 15 LENGTH: 674 words HEADLINE: Bush Promises Attempts to End Discrimination BYLINE: By Marie Cocco. Newsday Washington Bureau DATELINE: Washington KEYWORD: NATIONAL URBAN LEAGUE; MEETING; GEORGE BUSH; CIVIL RIGHTS; DISCRIMINATION; MINORITY; BODY: President George Bush, in his first speech to a major civil rights organization since taking office, pledged yesterday to "make America open and equal to all" by striking down barriers to minorities' economic advancement and working to ensure that discrimination ends. "Your problems are my problems," the president told thousands of delegates to the National Urban League convention here. "Today, I offer you my hand and offer you my word. Together, we will make America open and equal to all." But the president did not spell out new initiatives, and reiterated the list of tax breaks for business investors that he has proposed to spur inner city development. And Bush avoided any reference to a series of actions by his administration that already have strained relations between the White House and some civil rights leaders. These include Bush's controversial nomination of William Lucas - who last week was rejected as unqualified by the Senate Judiciary Committee - to head the Justice Department's civil rights division, and his decision that no legislation is needed to negate the string of recent Supreme Court decisions sharply limiting affirmative action. Bush's remarks got a polite reception from the delegates, who interrupted his speech at various points with a smattering of applause. Leaders of the Urban League and several delegates said afterward that while they disagreed with some of the president's views and actions, they were willing to give him more time to match his rhetorical commitment to civil rights with concrete deeds. Bush said his administration was open to reaching out to minorities, and said: "We will not tolerate discrimination, bigotry or bias of any kind, period." Bush suggested that affirmative action programs are no longer necessary, because he said a shortage of labor in the coming decade will mean jobs for women, minorities and immigrants. LEXIS® NEXIS® LEXIS® NEXIS Services of Mead Data Central PAGE 22 43RD STORY of Level 2 printed in FULL format. Copyright (c) 1989 The Times Mirror Company; Los Angeles Times July 1, 1989, Saturday, Home Edition SECTION: Part 1; Page 2; Column 1; National Desk LENGTH: 608 words HEADLINE: BUSH MARKS ANNIVERSARY OF CIVIL RIGHTS ACT, URGES EXPANDED FIGHT AGAINST BIAS BYLINE: By JAMES GERSTENZANG, Times Staff Writer DATELINE: WASHINGTON BODY: President Bush, declaring "the full promise of the civil rights movement has still not been achieved,' called Friday for an expansion of the civil rights mission in the United States to encompass the fight against discrimination based not just on race, but on gender, age and physical disabilities. During the day, the President also offered support to a number of other causes. He met with Albertina Sisulu, wife of an imprisoned black South African leader and co-president of the United Democratic Front of South Africa, who said later that Bush told her he hoped his Administration would become a catalyst "for bringing about a peaceful change in South Africa." However, she reported, the President balked at her call for "comprehensive, mandatory sanctions" seeking to bring about an end to South Africa's racial separation policy, apartheid. And, journeying across the Potomac to the flag-bedecked Iwo Jima Memorial in Arlington, Va., Bush gave his backing to a proposed 20-word constitutional amendment that would prohibit the desecration of the American flag. With an audience of civil rights leaders including the Rev. Jesse Jackson looking on in the White House East Room, Bush marked the 25th anniversary of the landmark 1964 Civil Rights Act, which President Lyndon B. Johnson signed into law on July 2, 1964. The act banned segregation in public accommodations and was followed by laws protecting voting rights and banning discrimination in housing and employment. Economic Barriers "The law cannot tolerate any discrimination and my Administration will not tolerate abuse of that principle," Bush said. "The hard lesson of the passing years is that it has not been enough to wage a war against the old forms of bigotry and inequality," he said. "The lives of the disadvantaged in this country are affected by economic barriers at least as much as by the remnants of legal discrimination." LEXIS® NEXIS® ® LEXIS® NEXIS® ® Services of Mead Data Central PAGE 23 (c) 1989 Los Angeles Times, July 1, 1989 While "much progress" has been achieved since the Civil Rights Act was passed, Bush said, it is time "to move forward on a broader front, to move forward into the century's final decade with a civil rights mission that fully embraces every deserving American, regardless of race, whether women, children or the aged; whether the disabled, the unemployed or the homeless." The President's 200 guests included civil rights leaders Martin Luther King III, Benjamin L. Hooks, Vernon Jordan, James Farmer and Rosa Parks, whose refusal to move to the back of a Montgomery, Ala., bus on Dec. 1, 1955, became a landmark in the civil rights movement. After the ceremony, Jackson complained that as a result of recent Supreme Court decisions restricting affirmative action programs and making it more difficult for plaintiffs to prove workplace discrimination, "we need a meeting of some substance with the President to deal with legislative remedies to offset" the impact of the court decisions. At the flag ceremony, Bush again showed his dismay with a Supreme Court decision that overturned laws in 48 states that made it illegal to burn the American flag. In a 5-4 decision last week, the court ruled that such statutes violated the First Amendment's protection of free speech. Using as a backdrop the bronze sculpture of the raising of the American flag on Mt. Suribachi during the victorious World War II battle for the Pacific island of Iwo Jima, Bush said: "For those who've championed the cause of civil rights here at home, to those who fought for democracy abroad, free speech is a right that is dear and close to all. It is in defense of that right and the others enshrined in our Constitution that so many have sacrificed." GRAPHIC: Photo, COLOR, Heroic Setting President and Mrs. Bush pose at the Iwo Jima Memorial in Arlington, Va., Friday before Bush gave his backing to a 20-word constitutional amendment that would prohibit the desecration of the American flag. United Press International SUBJECT: CIVIL RIGHTS; CIVIL RIGHTS ACT OF 1964; BUSH, GEORGE; FLAGS; DESECRATION; AFFIRMATIVE ACTION; DISCRIMINATION LEXIS® NEXIS® LEXIS® NEXIS entral PAGE 6 17TH STORY of Level 1 printed in FULL format. Copyright (c) 1989 The New York Times Company; The New York Times August 9, 1989, Wednesday, Late Edition - Final SECTION: Section A; Page 24, Column 1; National Desk LENGTH: 931 words HEADLINE: Bush Vows Rights Effort on Jobs and Economic Development BYLINE: By JULIE JOHNSON, Special to The New York Times DATELINE: WASHINGTON, Aug. 8 BODY: President Bush renewed the Administration's commitment to equal opportunity today, pledging to rebuild the nation's urban areas by focusing on education, job training and economic development. want to make sure everyone in this room knows just where I stand, just where my Administration stands, Mr. Bush told the annual conference of the National Urban League here. ' 'My Administration is committed to reaching out to minorities, to striking down barriers to free and open access. We will not tolerate discrimination, bigotry or bias of any kind, period. Mr. Bush used his appearance, the first by a President before the group since 1977, to continue White House efforts to build support among black Americans and civil rights groups, who were frequently at odds with Ronald Reagan's Administration and who have clashed in recent months with Mr. Bush's. 'Your problems are my problems, the President said. ''Today, I offer you my hand. I offer you my word. Together, we will make American open and equal to all. Touchy Issues Avoided But Mr. Bush avoided mention of issues that have recently angered civil rights groups, like the Supreme Court rulings that they said narrowed anti-discrimination laws, or his nomination of William C. Lucas to be head of the Justice Department's civil rights division, a choice that was rejected by the Senate Judiciary Committee. Mr. Lucas, a black former Executive of Wayne County, Mich., was criticized as lacking the legal experience needed to be the nation's top civil rights enforcement official. Mr. Bush has won high marks from civil rights groups for embracing affirmative action and working behind the scenes on legislation like amendments to the the Fair Housing Act and the Americans with Disabilities Act. Weighing against Mr. Bush among some civil rights leaders is his refusal when he was Vice President to criticize President Reagan on his actions on civil rights issues, like his veto of the Civil Rights Restoration Act. That measure was in response to a 1984 Supreme Court decision limiting the scope of LEXIS® NEXIS® LEXIS® NEXIS Services of Mead Data Central PAGE 7 (c) 1989 The New York Times, August 9, 1989 anti-distrimination provisions connected with the use of Federal money. Congress later overrode Mr. Reagan's March 1988 veto. League Focuses on Business Today, Mr. Bush was received warmly by the Urban League members, who interrupted his speech with applause several times. He tailored his remarks to the league, a civil rights organization that works closely with businesses and focuses on employment and economic development. Repeating his support for tax incentives to encourage business enterprises to locate in the inner cities, Mr. Bush said, ' 'The future of urban America depends on bringing growth to our inner cities. John E. Jacob, the league's president, praised Mr. Bush for language that he said sets a new tone for the nation on civil rights, and he said the President's positions on education and drugs were in line with those of the Urban League. 'What WE heard from him today is that he has said his Administration will do everything within its power to make sure that discrimination does not exist in this country and that they will fight it with every weapon that they have, Mr. Jacob said. ''I think that's important because this nation needs to have not only a reordering of its priorities but a reordering of the nation's atmosphere, to move the nation back toward the center. Speech Seen as Lacking Specifics But Clarence L. Barney, the New Orleans Urban League president, who is chairman of the national group's economic development committee, said Mr. Bush had to be assessed by his policies. 'Though I was very impressed with the tone, style and sincerity of the President's speech, I would like to have seen a greater degree of specificity, he said. He praised Mr. Bush's comment that the nation must 'create conditions for urban growth and economic revival. But Mr. Barney said it was unrealistic for black contractors to focus solely on inner cities with hopes of building 'economic wealth out of poverty. Mr. Barney said black business leaders 'want to rebuild our inner city neighborhoods, but we don't want to be consigned or restricted to that, adding, 'The greatest opportunities are in foreign investment and in rebuilding our infrastructure. It is estimated that $1.4 trillion will have to be spent in coming years rebuilding the nation's deteriorating highways, waterways and other public structures. Appearance Was Monitored Several civil rights organizations and Administration officials, particularly those who have been involved in skirmishes with the Bush White House, closely monitored Mr. Bush's appearance at the Urban League meeting, which concludes Wednesday. LEXIS® ® NEXIS® LEXIS® NEXIS R Services of Mead Data Central PAGE 8 (c) 1989 The New York Times, August 9, 1989 Ralph Neas, executive director of the Leadership Conference on Civil Rights, a coalition of several groups that helped marshal opposition to the nomination of Mr. Lucas, said, ''Everyone in the civil rights community applauds the new tone that President Bush has set, and this speech is another indication of that tone. But despite the oratory, Mr. Neas said, many groups in his coalition are 'deeply disappointed'' that Mr. Bush sees no need for the proposed legislation to counteract Supreme Court rulings that made it harder to bring and win suits charging discrimination. William Barclay Allen, chairman of the Civil Rights Commission, said in an interview after reading a text of the President's remarks: ''It's nice to have this statement. These are very important problems, but we must also recognize that civil rights is bigger. SUBJECT: URBAN AREAS; FEDERAL AID (US); CIVIL RIGHTS; EDUCATION AND SCHOOLS; LABOR; ECONOMIC CONDITIONS AND TRENDS ORGANIZATION: URBAN LEAGUE, NATIONAL NAME: BUSH, GEORGE (PRES); JACOB, JOHN E; JOHNSON, JULIE LEXIS® ® NEXIS® R LEXIS® NEXIS ® 204 FAMOUS SERMONS AND PUBLIC ADDRESSES IF THE chinery, has the capacity to make some miracles for men-if it values ous and vicious obstacle when th men as highly as it values machines. ployment. Labor must honestly To find a great design to solve a grave problem labor will have to in- design the battle plan which will tervene in the political life of the nation to chart a course which distrib- labor would be unearthing th utes the abundance to all instead of concentrating it among a few. The against the bleakness of injustic strength to carry through such a program requires that labor know its How can labor rise to the he friends and collaborate as a friend. If all that I have said is sound, labor cement its bonds with Negroes has no firmer friend than the twenty million Negroes whose lives will be First: Labor should accept the deeply affected by the new patterns of production. to Negroes and the struggle for To say that we are friends would be an empty platitude if we fail to taken actions to eliminate discr behave as friends and honestly look to weaknesses in our relationship. high enough the standard for Unfortunately there are weaknesses. Labor has not adequately used its should and can set an example f great power, its vision and resources to advance Negro rights. Undeni- sades for social justice. You shoi ably it has done more than other forces in American society to this end. tion of discrimination so that S( Aid from real friends in labor has often come when the flames of strug- or locals may not besmirch the gle heighten. But Negroes are a solid component within the labor move- aware this is not easy nor popul: ment and a reliable bulwark for labor's whole program, and should ex- ular nor easy to achieve. Nor W pect more from it exactly as a member of a family expects more from his you accomplished all of these relatives than he expects from his neighbors. Out of such struggle for democi Labor, which made impatience for long-delayed justice for itself a vi- and the respect of the country, tal motive force, cannot lack understanding of the Negro's impatience. Negro rights a great crusade. It cannot speak, with the reactionaries' calm indifference, of progress Second: The political strengt around some obscure corner not yet possible even to see. There is a mation from becoming a Molo maxim in the law-justice too long delayed, is justice denied. When a can be multiplied if you tap the Negro leader who has a reputation of purity and honesty which has Negroes, given the vote, will V benefited the whole labor movement criticizes it, his motives should not the same liberal legislation labo be reviled nor his earnestness rebuked. Instead, the possibility that he is To give just an example of th revealing a weakness in the labor movement which it can ill afford, I might cite the arresting fact t should receive thoughtful examination. A man who has dedicated his pealed the right-to-work law is ] long and faultless life to the labor movement cannot be raising ques- Negro vote in that state grew la tions harmful to it any more than a lifelong devoted parent can become er, and it went along with labor the enemy of his child. The report of a committee may smother with support to assist us in securing legal constructions a list of complaints and dispose of it for the day. But tween success and defeat for u if it buries a far larger truth it has disposed of nothing and made justice we need and you have an appar more elusive. ognized five years ago a moral eral of your leaders, including and Mr. MacDonald and othe BIAS EXISTS IN UNIONS paign to assist the struggling N Discrimination does exist in the labor movement. It is true that orga- circumstances in the South. A t nized labor has taken significant steps to remove the yoke of discrimina- ed by the ILGWU to begin the tion from its own body. But in spite of this, some unions, governed by the drive was never begun. Tl the racist ethos, have contributed to the degraded economic status of these turbulent, violent years, the Negro. Negroes have been barred from membership in certain many unions thought of as im unions, and denied apprenticeship training and vocational education. In meeting the budget to properly every section of the country one can find local unions existing as a seri- that you tax your treasuries. IF THE NEGRO WINS, LABOR WINS / 205 ous and vicious obstacle when the Negro seeks jobs or upgrading in em- ployment. Labor must honestly admit these shameful conditions, and design the battle plan which will defeat and eliminate them. In this way, labor would be unearthing the big truth and utilizing its strength against the bleakness of injustice in the spirit of its finest traditions. How can labor rise to the heights of its potential statesmanship and cement its bonds with Negroes to their mutual advantage? First: Labor should accept the logic of its special position with respect SPEECH TO AFV- c10 to Negroes and the struggle for equality. Although organized labor has taken actions to eliminate discrimination in its ranks, it has not raised high enough the standard for the general community. Your conduct should and can set an example for others, as you have done in other cru- sades for social justice. You should root out vigorously every manifesta- tion of discrimination so that some internationals, central labor bodies or locals may not besmirch the positive accomplishments of labor. I am aware this is not easy nor popular-but the eight-hour day was not pop- ular nor easy to achieve. Nor was outlawing anti-labor injunctions. But you accomplished all of these with a massive will and determination. Out of such struggle for democratic rights you won both economic gains and the respect of the country, and you will win both again if you make Negro rights a great crusade. Second: The political strength you are going to need to prevent auto- mation from becoming a Moloch, consuming jobs and contract gains, can be multiplied if you tap the vast reservoir of Negro political power. Negroes, given the vote, will vote liberal and labor because they need the same liberal legislation labor needs. To give just an example of the importance of the Negro vote to labor, I might cite the arresting fact that the only state in the South which re- pealed the right-to-work law is Louisiana. This was achieved because the Negro vote in that state grew large enough to become a balance of pow- er, and it went along with labor to wipe out anti-labor legislation. Thus, support to assist us in securing the vote can make the difference be- tween success and defeat for us both. You have organizing experience we need and you have an apparatus unparalleled in the nation. You rec- ognized five years ago a moral opportunity and responsibility when sev- eral of your leaders, including Mr. Meany, Mr. Dubinsky, Mr. Reuther and Mr. MacDonald and others, projected a two million dollar cam- paign to assist the struggling Negroes fighting bitterly in handicapped circumstances in the South. A ten-thousand-dollar contribution was vot- ed by the ILGWU to begin the drive, but for reasons unknown to me, the drive was never begun. The cost to us in lack of resources during these turbulent, violent years, is hard to describe. We are mindful that many unions thought of as immorally rich, in truth have problems in meeting the budget to properly service their members. So we do not ask that you tax your treasuries. Instead, we ask that you appeal to your SHOWDOWN FOR NONVIOLENCE / 67 es and the reforms that radiated get any instantaneous results from Congress, knowing its recalcitrant 1. nature on this issue, and knowing that so many resources and energies ties and five rural districts-from are being used in Vietnam rather than on the domestic situation. So we adre. We will have two hundred don't have any illusions about moving Congress in two or three weeks. But we do feel that, by starting in Washington, centering on Congress ild be about three thousand to get and departments of the government, we will be able to do a real educa- They are important, particularly They are being trained in this dis- tional job. We call our demonstration a campaign for jobs and income because we feel that the economic question is the most crucial that black people, e are also stimulating activities in and poor people generally, are confronting. There is a literal depression rotest. We are planning to have in the Negro community. When you have mass unemployment in the gton. We may have half the group Washington and begin the protest Negro community, it's called a social problem; when you have mass un- employment in the white community, it's called a depression. The fact king. They would flow across the is, there is a major depression in the Negro community. The unemploy- the Georgia group, right on up ment rate is extremely high, and among Negro youth, it goes up as high and Virginia. We hope that the as forty percent in some cities. oor people walking slowly toward We need an economic bill of rights. This would guarantee a job to all natic effect on Congress. 1, there will be spontaneous sup- people who want to work and are able to work. It would also guarantee an income for all who are not able to work. Some people are too young, he country. This has usually hap- some are too old, some are physically disabled, and yet in order to live, nk it will again. I think people will they need income. It would mean creating certain public-service jobs, choose California and other areas but that could be done in a few weeks. A program that would really deal em of transporting marchers that with jobs could minimize-I don't say stop-the number of riots that spontaneous demonstrations take could take place this summer. Our whole campaign, therefore, will center on the job question, with t is very important. We know from other demands, like housing, that are closely tied to it. We feel that president won't do anything until much more building of housing for low-income people should be done. ich people of goodwill can find a On the educational front, the ghetto schools are in bad shape in terms : it really means breaking that co- of quality, and we feel that a program should be developed to spend at n-dominated, rural-dominated, ba- least a thousand dollars per pupil. Often, they are so far behind that Southerners there with committee they need more and special attention, the best quality education that D stand in the way of progress as can be given. ght-wing midwestern or northern These problems, of course, are overshadowed by the Vietnam war. We'll focus on the domestic problems, but it's inevitable that we've got ement powerful enough, dramatic to bring out the question of the tragic mix-up in priorities. We are so that people of goodwill, the spending all of this money for death and destruction, and not nearly students, poor people themselves enough money for life and constructive development. It's inevitable en to the point that they can no that the question of the war will come up in this campaign. We hear all this talk about our ability to afford guns and butter, but we have come to economic problem of the poor. We see that this is a myth, that when a nation becomes involved in this kind to do to appeal to Congress itself. of war, when the guns of war become a national obsession, social needs re geared toward educational pur- inevitably suffer. And we hope that as a result of our trying to dramatize nature of the problem and the cru- this and getting thousands and thousands of people moving around this S that we confront in the ghettos. issue, that our government will be forced to reevaluate its policy abroad response from Congress, we will in order to deal with the domestic situation. igh to feel that we aren't going to 150 / PHILOSOPHY THE RISING TIDE OF ica in spite of these crippling restrictions is sufficient to refute all of the preventing our democratic and Cl myths and half-truths disseminated by the segregationist. Then and only then will we be ab Yet we cannot ignore the fact that our standards do often fall short. dream of our American democracy One of the sure signs of maturity is the ability to rise to the point of self- of equality of opportunity, of privil criticism. We have been affected by our years of economic deprivation a dream of a land where men will n and social isolation. Some Negroes have become cynical and disillu- give luxuries to the few; a dream of sioned. Some have so conditioned themselves to the system of segrega- the color of a man's skin determi tion that they have lost that creative something called initiative. So many dream of a place where all our gift have used their oppression as an excuse for mediocrity. Many of us live selves alone but as instruments of above our means, spend money on nonessentials and frivolities, and fail dream of a country where every m to give to serious causes, organizations, and educational institutions that of all human personality, and mei so desperately need funds. Our crime rate is far too high. ers-that is the dream. Whenever bleak and desolate midnight of ma and glowing daybreak of freedom CONSTRUCTIVE ACTION Therefore there is a pressing need for the Negro to develop a positive program through which these standards can be improved. After we have analyzed the sociological and psychological causes of these prob- lems, we must seek to develop a constructive program to solve them. We must constantly stimulate our youth to rise above the stagnant level of mediocrity and seek to achieve excellence in their various fields of en- deavor. Doors are opening now that were not open in the past, and the great challenge facing minority groups is to be ready to enter these doors as they open. No greater tragedy could befall us at this hour but that of allowing new opportunities to emerge without the concomitant preparedness to meet them. We must make it clear to our young people that this is an age in which they will be forced to compete with people of all races and nationalities. We cannot aim merely to be good Negro teachers, good Negro doctors, or good Negro skilled laborers. We must set out to do a good job irre- spective of race. We must seek to do our life's work so well that nobody could do it better. The Negro who seeks to be merely a good Negro, whatever he is, has already flunked his matriculation examination for entrance into the university of integration. This then must be our present program: nonviolent resistance to all forms of racial injustice, even when this means going to jail; and bold, constructive action to end the demoralization caused by the legacy of slavery and segregation. The nonviolent struggle, if conducted with the dignity and courage already shown by the sit-in students of the South, will in itself help end the demoralization; but a new frontal assault on the poverty, disease, and ignorance of a people too long deprived of the God-given rights of life, liberty, and the pursuit of happiness will make the victory more certain. We must work assiduously and with determined boldness to remove YWCA Magazine (December 1960): 4 from the body politic this cancerous disease of discrimination which is THE RISING TIDE OF RACIAL CONSCIOUSNESS / 151 preventing our democratic and Christian health from being realized. Then and only then will we be able to bring into full realization the dream of our American democracy-a dream yet unfulfilled. A dream of equality of opportunity, of privilege and property widely distributed; a dream of a land where men will not take necessities from the many to give luxuries to the few; a dream of a land where men to not argue that the color of a man's skin determines the content of his character; a dream of a place where all our gifts and resources are held not for our- selves alone but as instruments of service for the rest of humanity; the dream of a country where every man will respect the dignity and worth of all human personality, and men will dare to live together as broth- ers-that is the dream. Whenever it is fulfilled we will emerge from the bleak and desolate midnight of man's inhumanity to man into the bright and glowing daybreak of freedom and justice for all of God's children. YWCA Magazine (December 1960): 4-6. 366 INTERVIEWS PLAYBOY INTERVIEW: soul-searching analyses and evaluations of the environment- An example is aid to al causes that spawn riots. All major industrial and ghetto policy of the federal go areas should establish serious biracial discussions of commu- erty; one billion was p1 nity problems, and of ways to begin solving them. Instead of ing the slightest dent in ambulance service, municipal leaders need to provide pre- ple is the fact that aft ventive medicine. Secondly, these communities should when it became policy make serious efforts to provide work and training for unem- military machine the V ployed youth, through job-and-training programs such as took upon itself, throug the HARYOU-ACT program in New York City. Thirdly, all sures, the financial rel cities concerned should make first-priority efforts to pro- European people. If A vide immediate quality education for Negro youth-instead allies and ex-enemies, of conducting studies for the next five years. Young boys much greater obligatio and girls now in the ghettos must be enabled to feel that its own no less needy C they count, that somebody cares about them; they must be PLAYBOY: Do you feel it's fair to r able to feel hope. And on a longer-range basis, the physical of preferential treatme ghetto itself must be eliminated, because these are the envi- minority group? ronmental conditions that germinate riots. It is both socially KING: I do indeed. Can any fa and morally suicidal to continue a pattern of deploring ef- gro has been deprived? fects while failing to come to grips with the causes. Ultimate- turies the Negro was el ly, law and order will be maintained only when justice and potential accrued wealt dignity are accorded impartially to all. of his descendants. All PLAYBOY: Along with the other civil rights leaders, you have often adequately compensate proposed a massive program of economic aid, financed by ploitation and humiliati the federal government, to improve the lot of the nation's gram such as I propose twenty million Negroes. Just one of the projects you've computaton of two cent mentioned, however-the HARYOU-ACT program to lated interest. In any ca: provide jobs for Negro youths-is expected to cost 141 mil- of economic aid should lion dollars over the next ten years, and that includes only benefit the disadvantag Harlem. A nationwide program such as you propose would Within common law, undoubtedly run into the billions. cial compensatory prog KING: About fifty billion, actually-which is less than one year of ments. American India our present defense spending. It is my belief that with the settlement manner. Is expenditure of this amount, over a ten-year period, a genu- helped to build this cour ine and dramatic transformation could be achieved in the er easily applicable prec conditions of Negro life in America. I am positive, more- labor laws, social secur over, that the money spent would be more than amply justi- manpower retraining P fied by the benefits that would accrue to the nation through that America adopted a a spectacular decline in school dropouts, family breakups, millions of veterans aft crime rates, illegitimacy, swollen relief rolls, rioting and far more than a policy o other social evils. tate the traditionally PLAYBOY: Do you think it's realistic to hope that the government today. would consider an appropriation of such magnitude other The closest analogy is than for national defense? bilitation in America wo KING: I certainly do. This country has the resources to solve any breadth of program-w problem once that problem is accepted as national policy. den on our economy. Ji PLAYBOY INTERVIEW: MARTIN LUTHER KING, JR. / 367 An example is aid to Appalachia, which has been made a policy of the federal government's much-touted war on pov- erty; one billion was proposed for its relief-without mak- ing the slightest dent in the defense budget. Another exam- ple is the fact that after World War II, during the years when it became policy to build and maintain the largest military machine the world has ever known, America also took upon itself, through the Marshall Plan and other mea- sures, the financial relief and rehabilitation of millions of European people. If America can afford to underwrite its allies and ex-enemies, it can certainly afford-and has a much greater obligation, as I see it-to do at least as well by its own no less needy countrymen. PLAYBOY: Do you feel it's fair to request a multibillion-dollar program of preferential treatment for the Negro, or for any other minority group? KING: I do indeed. Can any fair-minded citizen deny that the Ne- gro has been deprived? Few people reflect that for two cen- turies the Negro was enslaved, and robbed of any wages- potential accrued wealth which would have been the legacy of his descendants. All of America's wealth today could not adequately compensate its Negroes for his centuries of ex- ploitation and humiliation. It is an economic fact that a pro- gram such as I propose would certainly cost far less than any computaton of two centuries of unpaid wages plus accumu- lated interest. In any case, I do not intend that this program of economic aid should apply only to the Negro; it should benefit the disadvantaged of all races. Within common law, we have ample precedents for spe- cial compensatory programs, which are regarded as settle- ments. American Indians are still being paid for land in a settlement manner. Is not two centuries of labor, which helped to build this country, as real a commodity? Many oth- er easily applicable precedents are readily at hand: our child labor laws, social security, unemployment compensation, manpower retraining programs. And you will remember that America adopted a policy of special treatment for her millions of veterans after the war-a program which cost far more than a policy of preferential treatment to rehabili- tate the traditionally disadvantaged Negro would cost today. The closest analogy is the GI Bill of Rights. Negro reha- bilitation in America would require approximately the same breadth of program-which would not place an undue bur- den on our economy. Just as was the case with the return- BROWN V. BOARD EDUCATION - robbe intentrois. Defunked doctrine of separate but agoral. Children are best educated when ref pegregated. (-bow muchare have barn from other, But the grip of government. the four to We want to part that in the hands of people. Parents (: vauchers) BROWN V. BOARD OF EDUCATION was a 1954 decision of the U.S. Supreme Court that voided state laws and state constitutional provisions requiring or permitting the segregation of white and black children in public schools on the basis of race. Chief Justice Earl Warren, writ- ing for a unanimous court on May 17, 1954, held in Brown V. Board of Education of Topeka that such laws and provisions denied to black children the equal protection of the laws guar- anteed by the U.S. Constitution. &o The Topeka (Kans.) Board of Education had 152/29 established segregated elementary schools. Attor- neys for black children contended that the seg- regated schools were not equal and could not be made equal. A U.S. district court disagreed, but Warren wrote that to "separate them from others of similar age and qualifications solely because of their race generates a feeling of in- feriority that may affect their hearts and minds in a way unlikely ever to be undone." He added, "Separate educational facilities are in- herently unequal." On May 31, 1955, the court asked local courts to require "a prompt and rea- sonable start toward full compliance with the decision, and said that local administrative prob- lems should be resolved "with all deliberate speed." Opponents of desegregation criticized the court's reliance on psychological and sociologi- cal data. They contended that the court was in effect passing legislation and was encroaching on states rights. In later years the Supreme Court struck down attempts by state legislatures and local school boards to avoid compliance. color blindmeans no guotes Nobody 10 I have a dream that my four little children will one day live in a nation where they will wants then not be judged by the color of their skin, but by the content of their character. Ib. Jus I'm Fare the Dem. Baderhip will work w/we to a abilltor all Am for appor, Sepal gootar. Photo Copy Preservation Office of the Attorney General Washington, B.C. 20530 April 3, 1990 Honorable Edward M. Kennedy Chairman Committee on Labor and Euman Resources U.S. Senate Washington, D.C. 20510 Dear Chairman Kennedy: This letter presents the views of the Administration regarding S. 2104, the Civil Rights Act of 1990. The Administration is determined to help root out racial bias and bigotry and to guarantee equal opportunities for all Americans, and has proposed new legislation to attack discriminatory employment practices. Guided by the same principles, the Administration opposes as inconsistent with equal opportunity any legislation that would encourage quota systems or otherwise divide our society along racial lines. If S. 2104 were presented to the President in its current form, I and other senior advisors would recommend that it be vetoed. The Administration's objections to S. 2104 are discussed below. Sections 1 through 3 of the bill are, respectively, the short title, statement of findings and purpose, and definitions. The substantive provisions of the bill begin with section =, which would reverse Wards Cove Packing Co. V. Atonio, 109 S. Ct. 2115 (1989). In Wards Cove, the Court addressed three important stages of a lawsuit alleging that an employer's hiring practices had the effect of discriminating in violation of Title VII of the Civil Rights Act of 1964. First, the Court reaffirmed that statistics may form the basis for a prima facie case of disparate impact. It also reaffirmed that the statistics must compare the employer's workforce to the pool of qualified job applicants or qualified members of the labor force. See, e.g., Hazelwood School District V. United States, 433 U.S. 299, 308 (1977) A second, related issue addressed by the Court involved causation. Consistent with established precedent, the Court noted that a Title VII plaintiff must identify the specific employment practice that has produced the challenged disparate impact. The Court then addressed the burdens imposed on the parties once a plaintiff has established a prima facie case of discrimination. The Court held that the employer's burden was to produce evidence that the "challenged practice pursues, in a significant way, the legitimate employment goals of the employer." Wards Cove, 109 S. Ct. at 2125-2126. The burden of persuasion, however, remains with the plaintiff. If the plaintiff does not meet this burden of persuasion, the plaintiff may still prevail by showing that reasonable alternatives would serve the employer's purpose equally well. S. 2104 would change the law in several respects. First, the bill would permit plaintiffs to allege simply that the end product of all the employer's employment practices was a statistically disparate workforce. The Court's approach seems to us to be a much more sensible, efficient, and fair allocation of litigation responsibilities. Absent the link between specific practices and a resulting disparate impact, employers could be found liable for the numerous innocent factors that can cause statistical imbalance in the composition of a workforce. Liability could be premised entirely on statistics showing "bottom line" racial imbalance, a measure of discrimination that the Supreme Court has appropriately rejected when bottom line balance has been offered as a justification for discriminatory selection devices. See Connecticut V. Teal, 457 U.S. 440 (1982) Moreover, asking the plaintiff to identify the specific practices that produce a disparate impact before employers are asked to justify them is consistent with traditional rules allocating burdens of proof. This allocation of responsibilities strikes us as more efficient and equitable than allowing plaintiffs simply to allege that a hiring system produces a disparate impact and forcing employers to demonstrate that each individual employment practice within that system does not have a disparate impact, as S. 2104 would. Furthermore, in view of the liberal discovery rules and the record-keeping requirements of the Uniform Guidelines on Employee Selection Procedures, 29 CFR 1607.1 et seq. (1988), we do not think that this requirement of specificity should unduly burden plaintiffs. Indeed, the Court's prior "disparate impact cases have always focused on the impact of particular hiring practices on employment opportunities for minorities," Wards Cove, 109 S. Ct. at 2124, and plaintiffs have always targeted those specific practices. See Griggs V. Duke Power Co., 401 U.S. 424 (1971) (high school diploma requirement) ; Dothard V. Rawlinson, 433 U.S. 321 (1977) (height and weight requirements for prison guards) ; Albemarle Paper Co. V. Moody, 422 U.S. 405 (1977) (employment tests and seniority systems) ; Connecticut V. Teal, 457 U.S. 440 (1982) (written examination) ; Watson V. Fort Worth Bank & Trust, No. 86-6139 (June 29, 1988) (subjective judgment of supervisor). 2 The Court's rule is also consistent with the general practice in the lower courts. S. 2104 would also shift the burden of persuasion to the employer and require that he prove that its employment practices are "essential to effective job performance." In our view, the Court correctly held that the burden of persuasion remains with the plaintiff throughout a disparate impact case, just as it does in a case alleging intentional discrimination, see Texas Department of Community Affairs V. Burdine, 450 U.S. 248, 256-258 (1981) and just as it generally does when causation is an element of a violation. See Restatement (Second) of Torts 433B (1965) This is also the accepted rule in civil litigation generally. Fed. R. Evid. 301. We think it would be unjustifiable to impose a greater burden on an employer who is alleged to have violated Title VII by employing a practice that produced a statistical imbalance than on one who is alleged to have engaged in purposeful discrimination. Even though the employer's burden is now established as one of production and not proof, it is by no means insubstantial. Under existing Supreme Court precedent (Texas Department of Community Affairs V. Burdine, 450 U.S. 248, 254-255 (1981)), the employer's burden is "to rebut the presumption of discrimination by "the introduction of admissible evidence" which is "legally sufficient to justify a judgment for the defendant." If the employer adduces evidence that an employment practice does pursue, in a significant way, legitimate employment goals, and if the plaintiff cannot then establish that such is not the case or that other reasonable alternatives are available, policy would not seem to dictate a result adverse to the employer. Likewise, we think that the Court's formulation of the applicable substantive standard is fully justified as an appropriate balancing of the interests of employers and employees. Prior decisions had used varying terminology in describing the employer's burden after a showing of disparate impact. See, e.g., Connecticut V. Teal, 457 U.S. 440, 446 (1982) (citation omitted) ("manifest relationship to the employment's) ; Albemarle Paper Co. V. Moodv, 422 U.S. 405, 425 (1975) ("job related") ; Gricos V. Duke Power Co., 401 U.S. 424, 431, 432 (1971) ("business necessity"; "manifest relationship to the employment") ; New York Transit Authority V. Beazer, 440 U.S. 568, 587 n.31 (1979) ("legitimate employment goals of safety and efficiency * * * are significantly served"). The standard molded by the Court from those prior formulations, i.e., that a "challenged practice serves, in a significant way, the legitimate employment goals of the employer" (Wards Cove, 109 S. Ct. 2125- 2126), has sufficient teeth to ensure that employers do not use practices of dubious business utility, while not pressuring employers to resort to hiring and promotion quetas, and respecting the needs of employers to preserve legitimate 3 management prerogatives. We find it unlikely that this formulation of the standard for a business justification will preclude the assertion of meritorious claims, particularly since the plaintiff may still prevail by showing that other reasonable business practices would satisfy the employer's need without producing a discriminatory effect. By contrast, the requirement of S. 2104 that an employer whose workforce is not statistically balanced show that each of its employment practices is "essential" to the conduct of the business puts the employer in a nearly impossible position. It would be difficult for the employer not to adopt a silent practice of quota hiring and promotion in an effort to protect the business from the probability of litigation wherever a statistical imbalance exists. Many employers would resort to using hiring criteria that would insure that the numbers come out "right." Those who say that Wards Cove represents a radical change in the law are simply wrong. Each of the Court's holdings was presaged by earlier Supreme Court and lower court decisions. These adjustments represent at most fine tuning to a method of proving discrimination that has been developed entirely by courts. We are convinced that the Court thoughtfully balanced the competing interests and produced a workable distillation of some eighteen years of precedents applying the disparate impact standard. Indeed, the Court in large part adopted the approach urged by a brief filed by the United States. This approach will enable employees to pursue successfully meritorious claims, and employers will not be unduly burdened in defending claims of discrimination. Nor will employers be encouraged to resort to quotas to ward off the threat of lawsuits based on statistical imbalances. Section 5 of the bill would reverse the holding in Price Waterhouse V. Hopkins, 109 S. Ct. 1775 (1989), in which the Court ruled in favor of a woman who alleged that she had been denied partnership by her accounting firm on account of her sex. The Court there faced a case in which plaintiff alleged that her sex had supplied part of the motivation for her rejection for partnership. The Court held that once she had established by direct evidence that sex played a substantial part in the decision, the burden shifted to the employer to show that it would have reached the same decision had sex not been considered. The result reached in Hopkins is as favorable or more favorable to plaintiffs as that adopted by the overwhelming (9-2) majority of courts of appeals. See id. at 1784 n.2. It is also consistent with the Supreme Court's own earlier decisions for mixed motive cases brought under the Constitution and the National Labor Relations Act. See Mt. Healthy City School District Board of Education V. Dovle, 429 U.S. 274 (1977) ; NLRB V. Transportation Management Corp., 462 U.S. 393 (1983) ; see also 4 Hunter V. Underwood, 471 U.S. 222 (1985). We think that the Court's balancing of interests is reasonable and should be preserved. Yet, S. 2104 would state that a violation of Title VII is established when the plaintiff demonstrates that race, color, religion, sex, or national origin was "a motivating factor" in an employment decision, regardless of whether the employer demonstrates that he would have made the same decision for legitimate reasons absent the discrimination. The latter proof would go only to the question whether the plaintiff was entitled to the position that he or she had been denied. The bill would reverse the general rule that in employment discrimination cases, as in any civil case, the plaintiff must show that the defendant's unlawful conduct caused the harm complained of by plaintiff. Allowing recovery based on an employer's state of mind is contrary not only to the spirit of Title VII, but to the spirit of our legal system as well. Of course, the inequities resulting from such an approach would be further magnified in the class action context. At the very least, reversal of Price Waterhouse is premature, since there was not a majority opinion for the Court and there is no evidence that the decision has worked inequitably. Moreover, the creation of this new category of Title VII violation would have an exacerbating effect if section 8 of the bill were enacted, authorizing compensatory and punitive damage awards for disparate treatment violations of Title VII. A plaintiff would be entitled to such awards and attorney fees even if the employer demonstrated that he would have made the same employment decision he did for legitimate reasons absent the discriminatory factor. Section 6 of the bill would reverse the holding in Martin V. Wilks, 109 S. Ct. 2180 (1989). That case arose in the context of a civil rights action, but it turned on principles of fairness and access to court that apply in every area. The Court held that white firefighters, who had not been parties to a consent decree that mandated racial preferences, could have their day in court to contend that the decree violated their civil rights. The Court rejected the so-called collateral attack doctrine, pursuant to which some courts had held that, once a decree was entered, it could not be challenged, even by individuals who had not been parties to the original lawsuit. The Court's decision turned on a straightforward application of the Federal Rules of Civil Procedure and underlying notions of due process. The Federal Rules establish procedures for joinder of all interested parties in a case. Quite simply, and quite fairly, anyone who is not joined in the lawsuit and given an opportunity to appear in court to protect his or her rights cannot be bound by the final judgment. The Court's decision is a reaffirmation of the fundamental notion that everyone is entitled 5 to his or her day in court. The Department of Justice advocated the position adopted by the Court. S. 2104, however, would reverse this holding by prohibiting challenges to a Title VII decree by individuals who had notice of the proposed judgment and an opportunity to present objections to it or if the interests of the challenger were adequately represented by another individual who challenged the judgment. The bill would also forbid challenges if the court that entered the judgment determined that reasonable efforts were made to notify interested persons of the judgment. We strongly oppose this provision. Rather, we think that the rule in Wilks has a salutary effect. By requiring early joinder of all those who may be adversely affected by a lawsuit, the rule enables courts to consider the full range of interests affected by a proposed decree. The decision may lead to fairer, more carefully considered, and unassailable remedies for discrimination. It will discourage attempts to bargain away third party rights, rather than making whole the actual victims of discrimination. In addition, the participation of all of the affected parties in formulation of a decree should aid in its implementation. Successful, voluntary compliance with Title VII may depend upon the cooperation of a broad range of individuals. Involving as many of those individuals as possible in formulating the decree will lead to smoother and more effective implementation of the remedy for discrimination. We view this decision working in conjunction with our proposed amendment to alter the statute of limitations in response to Lorance V. AT&T Technologies, Inc., 109 S. Ct. 2261 (1989), to ensure that aggrieved individuals have an opportunity to litigate their claims. In practice, the only time a consent decree will be disturbed under Wilks is when a federal judge finds that its operation is violating the rights of the challenging party. It is hard to understand why anyone would try to prevent such an adjudication. The unfortunate effect of this provision would be to insulate illegal or unconstitutional quota decrees from judicial review. Finally, by foreclosing appropriate review, the proposed Wilks legislation would raise serious constitutional concerns under the Due Process Clause of the Fifth Amendment. In particular, proposed section (III) (1) (B) of Section 6 of the bill would authorize the deprivation of an individual's legal claims without any attempt to notify the individual that his rights were in jeopardy. Rather, it would suffice that a court found that the individual's interests had been represented adequately by another party, regardless of whether the excluded individual stood in privity or in some similar relationship with the representative party. This provision of the bill is inconsistent with the Due Process Clause and "principle of general application in Anglo-American jurisprudence that one is not bound by a 6 judgment in personam in a litigation in which he is not designated as a party or to which he has not been made a party by service of process. Martin V. Wilks, 109 S. Ct. 2184, quoting Hansberry V. Lee, 311 U.S. 32. 40 (1940) (black home buyers could not be bound by prior suit approving racially restrictive covenant, since they had not been parties nor in privity with parties to the earlier suit). It also cannot be squared with the Supreme Court's consistent holding that notice is an "elementary and fundamental requirement of due process." Mullane V. Central Hanover Bank & Trust Co., 339 U.S. 306, 314 (1950). Proposed section (m) (1) (c) also raises serious due process concerns. This section would cut off future challenges to discriminatory employment practices if the court entering the judgment determined that "reasonable efforts were made to provide notice to interested persons." As discussed in the preceding paragraph, a general, and fundamental, principle in our legal system is that individuals are not bound by litigation in which they are not a party - that everyone is entitled to his or her day in court. This bill, moreover, differs considerably from other special statutory schemes approved by the Supreme Court where the need to resolve the ownership of specific property justifies foreclosing successive litigation by nonlitigants of preexisting claims. In contrast to the property interests affected by such statutory schemes, this bill precludes discrimination claims, including equal protection claims. Moreover, this bill purports to foreclose not only legal claims existing at the time of adjudication, but also claims that may arise in the future. Indeed, S. 2104 could foreclose claims which arose after judgment had been entered, based upon new acts of alleged discrimination occurring against, for example, individuals who had never previously applied for a job with the employer or, indeed, had not been born at the time of the original decree. Further, the procedure for determining the reasonableness of notice under section (m) (1) (c) is constitutionally defective. Such a proceeding would necessarily lack the adversarial character which normally gives us confidence in determinations reached by courts. Indeed, not only will the proceeding be nonadversarial, but defendants can be expected to support plaintiffs' claim to have provided reasonable notice. We do not believe an individual's due process rights are satisfied by a court determination entered with no one present to represent the individual's interests and where everyone who is present has interests contrary to those of the individual. Cf. Parklane Hosiery Co. v. Shore, 439 U.S. 322, 327 n.7 (1979) ; Blonder- Tonoue Laboratories, Inc. V. University of Illinois Foundation, 402 U.S. 313, 329 (1971). Section 8 of the bill provides for compensatory damages for intentional violations of Title VII and punitive damages when violations are committed with malice, or reckless or callous indifference to the rights of others. The section also expli- 7 citly acknowledges that any party will have a right to request a jury trial in an action for damages. This section represents a major change in Title VII and is in no way related to any of last Term's Court decisions. It was part of the original compromise that led to passage of Title VII that the only monetary relief available would be in the form of back pay. The scheme of relief authorized in Title VII reflected a careful balancing of employees' rights and the need to preserve legitimate management prerogatives. Title VII has proved effective in fighting exclusion of minorities and women from the workplace. The bill's proposal to authorize damages threatens to upset this careful balance. The bill's provisions for adding damages to the remedies already available will discourage conciliation and encourage litigation. Under the bill's regime, plaintiffs' lawyers will inevitably include claims for pain and suffering, emotional harm, and the like as a matter of course. Placing these issues before a jury, as well as the complex and emotional issues of liability that are often involved in Title VII cases, will turn Title VII litigation into a time-consuming, high risk venture for both plaintiffs and defendants. Thus, rather than adopt the bill's approach, we think it is better to preserve Title VII's current remedial scheme, with bench trials and prompt equitable relief including back-pay and rightful place seniority, which has worked well for over 25 years. The Administration endorses the bill's intent to change results reached in two of last Term's decisions: Lorance V. AT&T Technologies, Inc., 109 S. Ct. 2261 (1989), and Patterson V. McLean Credit Union, 109 S. Ct. 2363 (1989). The Administration has, however, itself proposed legislation to accomplish these results, and, for the reasons stated below, we urge the approach taken in the Administration's bill rather than S. 2104. Section 7 of S. 2104 would reverse the holding in Lorance V. AT&T Technologies, Inc., supra, in which female employees challenged a seniority system pursuant to Title VII, claiming that it was adopted with an intent to discriminate against women. Although the system was facially nondiscriminatory and treated all similarly situated employees alike, it produced demotions for plaintiffs, who claimed that the employer had adopted the seniority system intentionally to alter their contract rights. The Supreme Court held that the claim was barred by Title VII's requirement that a charge must be filed within 180 days (or 300 days if the matter can be referred to a state agency) after the alleged discrimination occurred. The Court held that the time for plaintiffs to file their complaint began to run when the employer adopted the allegedly discriminatory seniority system, since it was the adoption of the system with a discriminatory purpose that allegedly violated their rights. According to the Court, that was the point at 8 which plaintiffs suffered the diminution in employment status about which they complained. The Court viewed this result as dictated by its prior cases holding that the statute of limitations begins to run when the act of discrimination occurs and not when its effects are felt. The rule adopted by the Court was contrary to the position taken by the Government and the EEOC. It would shield large numbers of existing seniority systems from legitimate discrimination claims. The discriminatory reasons for adoption of a seniority system may become apparent only when the system is finally applied to affect the employment status of the employees that it covers. Moreover, such an application surely focuses the controversy between an employer and an employee more sharply and permits more precise litigation. In addition, a rule that limits challenges to the period immediately following adoption of a seniority system will promote unnecessary, as well as unfocused, litigation. Employees will be forced to challenge the system before it has produced any concrete impact or forever remain silent. Given such a choice, employees who might never suffer harm from the seniority system may be forced to choose to file a charge - an especially difficult choice since they may be understandably reluctant to initiate a lawsuit against an employer if they do not have to. And, finally, the Court's rule will prevent employees who are hired more than 180 (or 300) days after adoption of a seniority system from ever challenging the adverse consequences of that system, regardless of how severe they may be: Such a rule fails to protect sufficiently the important interest in eliminating employment discrimination that is embodied in Title VII. Likewise, a rule that an employee may sue only within 180 (or 300) days after becoming subject to a seniority system is unfair to both employers and employees. The rule fails to protect seniority systems from delayed challenge, since so long as employees are being hired someone will be able to sue. And, while this rule would give every employee a theoretical opportunity to challenge a discriminatory seniority system, it would do so, in most instances, before the employee's status had been adversely affected by the seniority system and, therefore, before the challenge was sufficiently focused and before it was clear that a challenge was necessary. Finally, most employees would be reluctant to begin their jobs by suing their employers. The Administration, therefore, supports an amendment to Title VII of the Civil Rights Act of 1964 that would start the period for filing a charge when a discriminatory system was adopted, when an employee becomes subject to the system, or when he is injured by it. 9 S. 2104 would address Lorance V. AT&T Technologies, Inc., supra, by adding the following sentence to Section 703 (h) of Title VII of the Civil Rights Act of 1964: Where a seniority system or seniority practice is part of a collective bargaining agreement and such system or practice was included in such agreement with the intent to discriminate on the basis of race, color, religion, sex, or national origin, the application of such system or practice during the period that such collective bargaining agreement is in effect shall be an unlawful employment practice. This provision contains two apparent and significant limitations. First it would apply only to seniority systems that are adopted as part of a collective bargaining agreement. Apparently, it would not apply to a non-union shop or where a seniority practice was not the result of a collective bargaining agreement or where a collective bargaining agreement had expired, but the seniority system remained in place. Second, this provision does not make explicit that an unlawful employment practice also occurs when a discriminatory seniority system is adopted and when an employee first becomes subject to it, even though it has not been "applied" in any tangible sense to the employee to produce some employment consequence. Rather, this amendment states only that the unlawful employment practice occurs when the system is applied. Thus, an employee may be precluded from challenging a discriminatory seniority system any time before it is applied to him or her. BY contrast, the Administration proposal is broader. It states: For purposes of this section, an unlawful employment practice occurs when a seniority system is adopted, when an individual becomes subject to a seniority system, or when a person aggrieved is injured by the application of a seniority system, or provision thereof, that was adopted for an intentionally discriminatory purpose, in violation of this Title, whether or not that discriminatory purpose is apparent on the face of the seniority provision. This proposal would reach all seniority systems, regardless of whether they were part of a collective bargaining agreement. It also makes explicit that an employee may challenge a 10 discriminatory system when it is adopted, when the employee first becomes subject to it, or when the employee suffers some injury by virtue of the application of the system. We, therefore, urge adoption of the Administration's language. Section I2 of S. 2104 would overrule Patterson V. McLean Credit Union, 109 S. Ct. 2363 (1989). In Patterson, an employee sued pursuant to 42 U.S.C. 1981, alleging that her employer had harassed her on the job, failed to promote her, and ultimately discharged her, all because of her race. The Court held that Section 1981 is limited by its terms to prohibiting discrimina- tion in "mak[ing] and enforc[ing] contracts," and does not extend to "problems that may arise later from the conditions of continu- ing employment." Patterson, 109 S. Ct. at 2372. Thus, the Court held, the statute prohibits discrimination - whether governmen- tal or private - in the formation of a contract and in the right of access to a legal process that will enforce established con- tract obligations without regard to race. While the plaintiff's allegation that she had been discriminatorily denied promotion might fall within the prohibition against discrimination in making contracts, her allegations of harassment on the job addressed only conditions of employment. And there was no allegation that she had been discriminatorily denied access to legal process to enforce her contract of employment. We believe that the law as interpreted in Patterson leaves a significant gap in section 1981 coverage that should be filled. We, therefore, support corrective legislation to ensure that section 1981 will apply to the performance, breach, and termination of contracts to the same extent that it does to their making and enforcement. Furthermore, to remove any possible ambiguity for future cases, we believe that it is appropriate to codify the holding of Runvon V. McCrary, 427 U.S. 160 (1976), that section 1981 prohibits private, as well as governmental discrimination. Again, however, we urge adoption of the language offered by the Administration. S. 2104 would overturn Patterson by adding the following sentence to 42 U.S.C. 1981: For purposes of this section, the right to "make and enforce contracts" shall include the making, performance, modification and termination of contracts, and the enjoyment of all benefits, privileges, terms and conditions of the contractual relationship. 11 The Administration bill would add the following new language: The rights protected by this section are protected against impairment by nongovernmental discrimination as well as against impairment under color of state law. This section affords the same protection against discrimination in the performance, breach, or termination of a contract, or in the setting of the terms or conditions thereof, as it does in the making or enforcement of that contract. The proposals are comparable in extending the protection of section 1981 to every aspect of contract performance and termination. The Administration proposal, however, goes beyond S. 2104 in codifying the holding of Runvon V. McCrary, 427 U.S. 160 (1976), that section 1981 reaches private, as well as governmental conduct. While the Supreme Court declined to overrule Runvon in Patterson, this provision ensures that Runyon will remain the law of the land. S. 2104 contains several changes to current civil rights law of less significance and varying degrees of merit, none of which appear necessary at present. Section 7 (a) (2) of S. 2104 would overturn much of the Supreme Court's jurisprudence regarding the time for challenging an unlawful employment practice. Under current law, an employee must challenge such a practice within 180 days after it "occurred." Section 7 (a) (2) would also permit such a challenge within 180 days after the unlawful practice had "been applied to affect adversely the person aggrieved." The selection of a starting point for the running of a statute of limitations initially involves a weighing of two important interests: (1) ensuring that as many meritorious claims as possible can be pursued, while (2) not unfairly burdening employers with the obligation to defend stale suits. The Court has generally designated the point at which the employee receives notice of an employment action as the relevant moment. See Delaware State College V. Ricks, 449 U.S. 250 (1980) i Chardon V. Fernandez, 454 U.S. 6 (1981) S. 2104 would go too far in upsetting the present balance. By focusing on the subsequent applications of an employment practice, rather than the occurrence of the practice, S. 2104 would allow charges to be filed long after --in many instances years after - the challenged practices occurred. Increasing the time between the challenged act and the filing of a charge will increase the likelihood that memories will fade, witnesses will disappear, and documents will be lost, making it more difficult for both plaintiffs and defendants to meet their respective burdens. 12 Similarly, section 7 (a) (1) would extend the statute of limitations for filing a charge of discrimination pursuant to Title VII from 180 days (or 300 days in a state that is certified as having a comparable procedure) to 2 years. We are aware of no body of proof that suggests a need for such prolongation of the existing filing rules. Instead, this additional time between the occurrence of the challenged practice and the charge will simply increase the likelihood that employers will have to defend against stale claims. It may also disadvantage some plaintiffs by lulling them into delaying assertion of their claims until their claims are stale and more difficult to prove. Likewise, Section 10 (1) of S. 2104 would extend the time for filing a charge against the federal government from 30 to 90 days. We are not convinced of the need for this change. The short filing deadline provides an opportunity for structured resolution of a grievance before positions become hardened. Section 9 of the bill addresses attorney and expert witness fees in Title VII actions. Section 9 (2) would authorize awards of the full amount of expert witness fees to prevailing parties. The fees presumably would be awarded according to the same standard that governs awards of attorney fees; that is, prevailing plaintiffs generally recover fees, while prevailing defendants recover if the plaintiff acted frivolously or unreasonably. The current state of the law regarding awards of expert fees is unsettled, and is likely to be resolved soon. The Supreme Court recently granted certiorari in West Virginia Hospital V. Casey, No. 89-994, to resolve whether the fees of expert witnesses may be included in an award of attorney fees pursuant to 42 U.S.C. 1988. Because the statutory language of section 1988 and Title VII is similar, that case should shed light on the question whether such fees may be recovered pursuant to Title VII. Legislation may prove to be premature, and the Court's thinking on the subject may provide instruction. Section 9 (3) of the bill would strike the language of section 706 (k) of Title VII that states that attorney fees shall be awarded "as part of the costs." This section would overturn Marek V. Chesny, 473 U.S. 1 (1985), in which the Court held that attorney fees awarded pursuant to 42 U.S.C. 1988 as part of the costs were subject to Rule 68 of the Federal Rules of Civil Procedure. Rule 68 states that when a timely pretrial offer of settlement is made and "the judgment finally obtained by the offeree is not more favorable than the offer, the offeree must pay the costs incurred after the making of the offer." Thus, Marek held that if a plaintiff rejects a pretrial offer and fails to recover more at trial, he may not recover from the defendant attorney fees incurred after the offer. 13 The Government supported this result as amicus curiae, and we are not convinced that the current rule fails to make sense as a matter of judicial administration. Rule 68 is designed to encourage settlement and avoid litigation. The inclusion of attorney fees as an expense that cannot be recovered serves those goals. Title VII is otherwise designed to encourage resolution of complaints prior to litigation and Rule 68 constructively reinforces that structure. The Administration is not aware that Marek has imposed substantial hardship. Section 9 (4) of the bill would prohibit a court from entering a consent decree unless the parties and their counsel attested that a waiver of attorney fees had not been compelled as a condition of the settlement. This provision would overturn Evans V. Jeff D., 475 U.S. 717 (1986), in which the Court held that a district court has discretion to approve a settlement that is conditioned on a waiver of statutory attorney fees. Again, the Government urged this result as amicus curiae. This provision is designed to eliminate a potential bind for attorneys. Where a defendant offers a favorable settlement, but conditions it on the attorney's waiver of any claim for attorney fees, the plaintiff's attorney will often disserve his client by rejecting the offer, but may forego compensation if he accepts. This provision, however, would eliminate a way in which defendants can limit their liability and be certain of the bottom line. In addition, a district court has discretion to reject a settlement that contains a compelled fee waiver. It may also instruct the parties to negotiate fees separately. In view of these safeguards, the Administration is not convinced that this provision is necessary. Section 9 (4) of S. 2104 would also authorize a party who prevailed in a Title VII action to recover from the party against whom relief was granted attorney fees incurred in defending that relief from subsequent collateral attack. This provision addresses indirectly the rule announced in Independent Federation of Flight Attendants V. Zipes, 109 S. ct. 2732 (1989), in which the Court held that individuals bringing a collateral attack would be treated as Title VII plaintiffs, not defendants, for attorney fee purposes -- i.e., the original plaintiffs would recover from them only if the collateral attack had been frivolous. The Government, as amicus curiae, once again supported this result. Pursuant to this provision of S. 2104, the cost of another party's unsuccessful - and perhaps frivolous or ill-advised - litigation would be imposed on a defendant who had no control over it. The Administration is not convinced that the solution offered by this provision is wise. 14 Section 10 of the bill, in addition to lengthening the statute of limitations for filing a charge against the federal government, would also authorize payment of interest on Title VII awards against the United States. Section 11 of S. 2104 would require that all civil rights statutes be broadly construed to effectuate their purposes. To the extent that this provision suggests that courts should eschew traditional rules of statutory construction in favor of unfettered judicial policymaking, we oppose it. Civil rights statutes, like all others, should be construed in a manner that is consistent with legislative intent as expressed in the language of the statutes. Section 11 of the bill further provides that no federal civil rights law shall be construed to "limit the rights, procedures, or remedies available under any other Federal law protecting such civil rights." Again, civil rights statutes should be construed and reconciled according to their language as enacted. To the extent that this provision suggests that courts do otherwise, we oppose it. Section 13 of the bill states that it shall not be construed to affect "court-ordered remedies, affirmative action, or concil- iation agreements that are otherwise in accordance with the law. The purpose of this section is unclear. It should be clarified so that it may be debated. Section 14 of the bill contains a severability provision. Section 15 of the bill creates transition rules. It states, in effect, that each provision that overrules a Supreme Court case shall apply retroactively to the date of the decision. It also provides for vacating orders entered in the interim and tolls until enactment of the bill the running of the statute of limitations on actions that were not filed because of one of the overturned decisions. By upsetting final judgments, this section may unconstitutionally interfere with vested legal rights. In conclusion, the Administration supports overruling Patterson and Lorance, but urges the Committee to adopt the language of the Administration's proposal. The Department vigorously opposes those parts of S. 2104 that would overturn Wards Cove Packing Co. V. Atonio, Martin V. Wilks, and Price Waterhouse V. Hopkins, as well as the bill's damage remedy for Title VII violations. Based upon this opposition, if S.R. 2104 were presented to the President in its current form, I and other senior advisors would recommend that it be vetoed. 15 The Office of Management and Budget has advised us that there is no objection to the submission of this report and that enactment of S. 2104 would not be in accord with the program of the President. CC: Honorable Orrin G. Hatch 16 CIVIL RIGHTS ACT OF 1990 by William J. Kilberg* The Civil Rights Act of 1990, currently before Congress, purports to seek a series of narrowly defined, undeniably laudable goals: to "restore" rights, "correct" statutes of limitation, "reform" rules of construction, and reassert the principle that "job bias is always illegal." In fact, the bill would overturn years of Supreme Court precedent reflecting the difficult balancing of societal dilemmas embedded in hard-fought civil rights legislation. Indeed, while eschewing any intent to mandate quotes, this bill would eliminate all defenses to employment practices that fail to assure proportionate hiring and promotion for minorities and women. Proponents of this legislation apparently view Supreme Court interpretations of the 1964 Civil Rights Act as a coherent challenge to the ability of the American workforce to *Mr. Kilberg served as Solicitor for the United States Department of Labor, 1973-77; he is a labor lawyer and partner in the Washington, D.C. office of Gibson, Dunn & Crutcher. become integrated racially and sexually. In fact, the tentative and factious Court has done no such thing. Rather, it has backed itself into a series of compromises that allow employers a degree of flexibility to adopt and implement affirmative action programs while denying plaintiffs the right to ride statistical disparities in the workforce to the point at which quotas become inexorable. One of the decisions criticized by the proposed legislation, Wards Cove Packing Co. V. Atonio, sets forth two complementary principles: (1) plaintiffs are responsible for isolating and identifying with specificity the employment practices that are allegedly responsible for any observed statistical disparities; and (2) employers must show that the "challenged practice serves, in a significant way, the legitimate employment goals of the employer." These holdings strike a carefully calculated balance between a plaintiff's difficulty in proving intent from an employer's subjective decisional process and an employer's difficulty in proving that subjective criteria are justified by business necessity. The Civil Rights Act of 1990 would reverse both portions of this compromise. Under this legislation, plaintiffs could rely on a generalized "group of employment practices" as the basis for a lawsuit. To prove business necessity, the employer would then -2- have to establish that the criterion applied was "essential to effective job performance." Thus, under the Civil Rights Act of 1990, plaintiffs would have to do nothing more than establish a statistical disparity; employers then would be liable unless they could identify specific reasons for the disparity and prove that each of the causes was essential for effective job performance. How do you prove that any particular subjective criterion, such as loyalty, integrity, or interpersonal skills, is "essential"? It is virtually impossible to do so. Thus, employers governed by such a standard would be left with little choice: either impose statistical quotas or risk large compensatory and punitive damage awards from the juries that now would decide such actions under the revised procedures contained in other portions of the bill. Similarly, the proposed legislation would radicalize the Supreme Court's 1989 decision in Price Waterhouse V. Hopkins, which sets forth standards under which plaintiffs may recover in so-called "mixed motive" cases. In Hopkins, the Court had to reconcile the difficult questions raised when evidence of both discriminatory and non-discriminatory motives for employment decisions is presented. The Court resolved these questions by holding that, once a plaintiff evidences some impermissible race-based or gender-based stereotypes, the -3- employer must assume the burden of proving that the same decision would have been made in the absence of these factors. Because requiring "clear and convincing" evidence concerning the latter issue would make proof virtually impossible, the Supreme Court held that the employer's burden would be governed by the "preponderance of the evidence" standard usually associated with civil actions in our legal system. Not satisfied with the plaintiff's victory in Hopkins, or even with a "clear and convincing" standard that would make the employer's burden nearly impossible, proponents of the Civil Rights Act are seeking to assure that the employers' burden in such cases is, in fact, impossible. Under the proposal, an unlawful employment practice would be found whenever "the complaining party demonstrates that race, color, religion, sex or national origin was a motivating factor for any employment practice, even though such practice was also motivated by other factors." The employer would thus be given no opportunity to prove that the adverse action would have resulted even in the absence of any discriminatory motive. Deputy Attorney General Donald B. Ayer put it succinctly in his testimony on the bill in the House of Representatives: "I believe that this would be the first instance ever in American law where damages could be recovered solely for thinking bad thoughts." -4- The Civil Rights Act of 1990 would thus appear to have as its primary effect, if not purpose, to stimulate lawsuits against employers. If enacted, it would surely succeed in that. It would not, however, create a single job, except perhaps for labor lawyers. Nor would the bill provide job skills for a single person. It ignores the two key changes coming to our workforce in the 1990's -- the increasing demand for skilled labor and the dramatic increase in the percentage of new entrants into the workforce who are minorities and women. Instead of dealing with the real issues resulting from changing demography, this bill would favor a race and gender-coded workforce hired and promoted by the numbers. The Civil Rights Act of 1990 is not an extension of prior congressional efforts to create a better society, but an effort that can only pervert the principles upon which that prior, historic legislative effort was founded. -5- reasury from the public, or the government argue that only reduction of the said in an interview. Myers IS con- current-account deficit will produce cerned that an over-generous Con- would have to cut spending or raise taxes elsewhere in the budget" to a meaningful economic benefit. gress could enact more generous TALKING POINTS Bush Meets With NAACP Chief, Cites 'Outrage' at Bombings President Bush yesterday met with NAACP Chair- man Benjamin Hooks to assure him that the admin- istration will "not let up" in investigating the recent wave of bombings aimed at civil rights figures. In a statement issued by the White House, Bush said he met with Hooks to "personally express to him my outrage" at the recent bombings, obscene phone calls and hate mail aimed at NAACP headquarters and branch chapters. "I have asked Reverend Hooks to let his membership know that this administration will not let up in the fight against racism and that we will O R work to bring the perpetrators of these hideous BUSH HOOKS crimes to justice," Bush said. Hooks said after the meeting that he is "fairly sat- Privately Financed 'Points of Light' isfied" with the efforts of federal authorities to inves- President Bush was presented last week with tigate the wave of bombings and threats. A federal recommendations for establishing a privately fi- TREAS judge and a lawyer involved in civil rights cases were nanced national volunteerism program-his own killed last month by mail bombs. Other mail bombs, "thousand points of light" program. sent to the courthouse in Atlanta and to an NAACP "We're recommending setting up a private-public office in Florida, were intercepted by authorities. foundation," said New Jersey Gov. Thomas H. Kean S Earlier, Bush signed a proclamation for next Mon- day's Martin Luther King holiday observance before a (R), chairman of the five-member President's Ad- group including Hooks. Bush, saying he wanted to visory Committee on the Points of Light Initiative. offer "some words from the heart," said King's life Although Bush has discussed a $50 million annual was "central to the story of America" and the holiday budget to get the initiative moving-$25 million is an event "that celebrates the greatness of a man from the private sector and another $25 million in whose life and legacy helped set America free." public money-Kean said the foundation should be- gin immediately without tax dollars. "Let's get it up States' Big Tab for Education, Welfare first as a private foundation so we can get it going Save 30% to 50% on selected fi State governments spent half their $485 billion right away," he said. outlays in fiscal 1988 on education and welfare, ac- The Points of Light Initiative Foundation, which and gold jewelry, giftware, sil cording to a recent Census Bureau report. would be composed of 19 to 25 board members, would seek to instill a desire for community service during our annual sale fo The bureau said $160 billion went for education and $84 billion for welfare. Highways, health and in the 50 percent of all Americans who never have hospitals, employee retirement, unemployment and volunteered, Kean said. other insurance trusts plus a variety of smaller pro- "I don't think there's a problem out there that can't grams accounted for the remaining expenditures. be helped by volunteers," Kean said. "That's not to JANUARY 11 The report said the two biggest sources of state replace what government should be doing. No matter revenue were state taxes, which produced $264 bil- what government does, it can never be enough." Connecticut lion, and federal government payments, $100 billion. Senator Hits Gains Tax 'Name-Calling' $150 Hourly Fees at Ethics Committee Metzenhaum (D-Ohio) yesterday A phlosophrating 800ydars ago said "Anticipate" charity by prevating poverty." Maimonids, 1190 Guide to the Peeplexed THE WALL STREET JOURNAL FRIDAY, MAY 4, 1990 The 1990 Civil Rights Bill Is Wrong By ABIGAIL THERNSTROM low 50% and a literacy test was used to use of numerical indicators has expanded Opposing a bill that has been named screen potential registrants. All states and to one that is highly questionable. Courts "The Civil Rights Act of 1990" is not politi- counties fitting those criteria were "cov- and the Justice Department have arrived cally easy: the deck has already been rhe- ered" and thus subject to a set of stringent at a new statistical rule of thumb: Where torically stacked. But the proposed legisla- remedies. minority officeholding is disproportionately tion is deeply flawed. The title of the bill At the time, critics complained that jus- low in relation to the minority population, and the voices of Coretta Scott King and tice could not be measured by percentages electoral exclusion can almost be assumed. others in support of it all suggest continu- and that fair enforcement of the Fifteenth Only blacks can represent blacks, it is ap- ity with the great- civil rights-statutes of Amendment required the precise identifi- parently believed, and black, candidates the 1960s. In fact. the issues the 1990 bill cation of offenders, which the statistical lose elections for only one reason: race. raises have none of the moral simplicity of formula did not provide. But in fact the act Those assumptions last week informed those earlier days. did not rely excessively on numerical indi- the Justice Department decision to throw It is the attempt to overturn last term's cators. Framed with meticulous care, in- out Georgia's system of electing judges. Supreme Court decision in Wards Cove formed by years of litigation experience. True. the number of superior court judges Packing Co. U. Atonio that is most trou- the 1965 statute swiftly accomplished what in the state is disproportionately low in bling. Employment patterns in an Alaskan no previous law had achieved: the enfran- relation to the black population. Even in salmon cannery were the issue in Wards chisement of Southern blacks. majority-black Atlanta. only three out of 11 Cove. The "non-cannery" jobs were gener- The statistical test allowed the finding judges are black. But how large is the pool ally held by whites, while Filipinos, Es- of vote denial by a simple formula, elimi- of qualified attorneys eager for judge- kimos and Aleuts filled most of the un- ships? How many black voters bother to skilled "cannery" positions. The plaintiffs charged discrimination. But how telling Within limits, num- cast ballots in judicial elections-contests that are often ignored by almost everyone? was the disproportionate concentration of bers are telling in discrimi- And how often does any candidate-white minority employees in the lower paying- or black-win against an incumbent? jobs? Not as telling as the plaintiffs claim, nation cases. No one Again, the numbers raise questions. But, the Supreme Court said. would argue otherwise. as the court in Wards Cove understood, Harder for Plaintiffs they don't provide the answers. But only in exceptional In voting rights cases, electoral defeat Civil rights groups depict the decision is not conclusive evidence of inadequate as a betrayal; the court reneged on an ear- circumstances should they electoral opportunity, and opportunity lier commitment, they say. And indeed, Wards Cove has made it harder for minor- be regarded as conclusive, should be the question. Likewise, the fail- ure to pass an employer's test is not strong ity plaintiffs to prevail. A 1971 decision Griggs v. Duke Power Co.) forced em- or nearly so. evidence of a system closed to minority as- pirations. The point of antidiscrimination ployers to defend their hiring practices as a "business necessity" if plaintiffs could nating the need to ferret out constitutional laws is not to protect black candidates violations in states with abominable rec- from white competition-whether the job point to a "racially disparate impact"- ords with respect to black voting rights. By in question is in politics or industry. Their fewer blacks than whites passing, say, an 1965 the excessive cost and limited effec- point is to provide access, and, again, only aptitude test. tiveness of the traditional judicial route in the most extraordinary circumstances The problem with Griggs was the as- had become abundantly clear. And what can access be gauged from statistical evi- sumption that numbers-the number of the framers of the act wrote into law was dence. Access normally raises a question blacks in one job category and the number only what the litigators had learned in the about process, not results. Is the elec- of whites in another-tell much of what field. The statistical test simply acknowl- toral-or hiring-process distorted by rac- you want to know in an employment dis- edged the proven link-proven in countless ism? Has opportunity been blocked by rac- crimination case. And the strength of suits-between fraudulently administered ist assumptions? Wards Cove was that it refined- an ele- Southern literacy tests and low levels of mentary, common-sense manner-the sta- Emphasis on Opportunity voter participation. Aware that literacy tistical rule. Minorities may be dispropor- tests were the chief means of disfranchis- An emphasis on opportunity, or fair pro- tionately concentrated in unskilled posi- ing Southern blacks, the framers of the cess, squares with our traditional and con- tions or may disproportionately fail an ap- 1965 act used voter registration and turn- tinuing understanding of what Americans titude or other test, the court said, but the are entitled to. To focus on numerical re- out figures to devise a statistical means to relevant question is the size of the pool of identify the discriminatory use of literacy sults is to invite quotas. And quotas minority candidates qualified to fill the amount to reserved seats for scheduled tests. jobs in question. And if the numbers alone But those circumstances were unique. castes, as in India where the horizons of tell less than the Griggs court assumed In 1965 low voter registration rates were trust do not extent beyond ethnic bounda- they would, then a showing of disparate an almost infallible guide to the intention- ries. That, too, is a lesson contained in the impact should not place the burden of ally discriminatory use of literacy tests. history of the Voting Rights Act. We can proof on employers to demonstrate the Equally important, citizens over 18, with take the path of pessimism-of assuming "business necessity" of their hiring proce- few exceptions, have a right to vote; that's that members of minority groups cannot dures. Plaintiffs who charge discrimina- what democracies are all about. Employ- get a "fair shake" and must be given their tion should have to prove their case. ment is very different. Statistical informa- "fair share." Within limits, numbers are telling in tion is not a comparably reliable sign of in- Or we can structure our legal system- discrimination cases. No one would argue tentional-discrimination-df a desire to ex- ,our electoral and-employment processes, otherwise. But only in exceptional circum- clude blacks from certain jobs. And no one among others-to deliver a message that stances should they be regarded as conclu- is entitled to a particular category of job in minority groups amount to separate na- sive, or nearly SO. The 1965 Voting Rights a particular place of employment. tions and separate nations require distinct Act is instructive in this regard. It was Thus, when it comes to jobs, numbers treatment. That message runs through precisely the point of the act to substitute a can serve to alert employers, employees much civil rights discussion these days. statistical rule of thumb for the extended and courts to the possibility of discrimina- But it should not inform our law. and complex judicial process by which Fif- tion. But numbers should only set off an in- teenth Amendment questions were tradi- quiry. Other questions must then take Mrs. Thernstrom is the author of tionally decided. The act identified a viola- over. Again, the history of the Voting "Whose Votes Count? Affirmative action tion wherever voter registration or turnout Rights Act is instructive. In the enforce- and Minority Voting Rights," (Harvard in the presidential election of 1964 fell be- ment of the statute, the initially legitimate University Press, 1987). PAGE. 001 MAY 8 '90 12:16 FROM WB FEAT LEGAL Whitery young Roy Inniss WARNER BROS. INC. FEATURE LEGAL 4000 WARNER BOULEVARD against fhotas BURBANK, CA 91522 TELEPHONE: 818-954-2023 FAX NO. (818) 954-3490 FACSIMILE COVER PAGE TO: CAROLYN CAWLEY FROM: JEREMY WILLIAMS COPIES TO: TOTAL NUMBER OF PAGES (INCLUDING COVER PAGE): 3' DATE: MAY 8, 1990 NOTE: IF YOU DO NOT RECEIVE ALL PAGES, PLEASE CALL (818) 954-2023 AND ADVISE US OF MISSING PAGES OR TELEX NUMBER: 4720389, 0677129 AND LEAVE MESSAGE ADVISING US OF THE PAGES MISSING YOU NEED. THANK YOU. Bill Bennett BUDGET NO.: 415107 FAX NO.: 202-456-6218 Terry Eastland "by #'s" # Ben Hooks John Jacobs "on quotes Bush" MAY 3 '90 12:16 FROM WB FEAT LEGAL PAGE. 002 WB WARNER BROS. Jeremy N. Williams Warner Bros. Inc. Vice President and General Counsel P Theatrical 4000 Warner Boulevard Burbank, California 91522 818 954-2023 Cable Address: Warbros May 8, 1990 VIA FAX (#202-456-6218) Carolyn Cawley THE WHITE HOUSE Washington Re: "DRIVING MISS DAISY" - King Quote Dear Ms. Cawley: Replying to your fax, I attach the page of the script in which the King voice overs appear. Best of luck with it. Sincerely, JNW/wa Janes Jeremy N. Williams Attachment 11" A Warner Communications Company MAY 8 '90 12:16 FROM WB FEAT LEGAL PAGE. 003 97.* * 139 EXT. BILTMORE SIDE DOOR - SAME TIME 139 Daisy emerges from her car, slowly but head held high. Hoke stands where he is, on his side of the car, not helping, his head also held high. This is an enormous breach of etiquette. Daisy proceeds into the hotel. Hoke climbs back into the car, his face troubled. He drives it slowly away from the arrival area. ON HOKE'S immobile face. 140 INT. BILTMORE HOTEL BALLROOM - NIGHT 140 The room is crowded with elegantly laid round tables, each seating eight. The camera concentrates on DAISY so we see only one end of the room. Nor do we see the speaker DR. KING, but only hear his voice, as the camera moves in slowly toward DAISY and the empty chair beside her. DR. KING (v.o.) Segregation has placed the whole south socially, educationally and economically behind the rest of the nation. Yet there are in the white south millions of people of goodwill whose voices are yet unheard, whose course is yet unclear, and whose courageous acts are yet unseen 141 INT. DAISY'S CAR - NIGHT 141 HOKE sits listening to the same speech on the car radio. DR. KING (v.o.) These persons are often silent today because of fear - fear of social, political and economic reprisals. In the name of human dignity, and for the cause of democracy these millions are called upon to gird their courage, to speak out, to offer leadership that is needed. 141A INT. BILTMORE HOTEL BALLROOM - NIGHT 141A* CU Daisy- DR. KING (v.o.) If the people of goodwill of the white south fail to act now, history will have to record that the greatest tragedy of this period of social transition was not the vitriolic words and the violent actions of the bad people, but the appalling silence and the indifference of the good people. Diane wear MLK Library 526-8989 524-1956 Archives Dingler Plaza Hotel after Nobel Prize 1/65 Atlanta See On by Neks King The Words of NICK, Jr green new market Price a a Testament of Hope The Writings of MLK Halper: 5. RDN by