Elmer Britton v. South Bend Community School Corporation

819 F.2d 766, 43 Fair Empl. Prac. Cas. (BNA) 1483, 1987 U.S. App. LEXIS 6536, 43 Empl. Prac. Dec. (CCH) 37,104
CourtCourt of Appeals for the Seventh Circuit
DecidedMay 18, 1987
Docket84-2841
StatusPublished
Cited by22 cases

This text of 819 F.2d 766 (Elmer Britton v. South Bend Community School Corporation) is published on Counsel Stack Legal Research, covering Court of Appeals for the Seventh Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Elmer Britton v. South Bend Community School Corporation, 819 F.2d 766, 43 Fair Empl. Prac. Cas. (BNA) 1483, 1987 U.S. App. LEXIS 6536, 43 Empl. Prac. Dec. (CCH) 37,104 (7th Cir. 1987).

Opinions

POSNER, Circuit Judge.

In 1982 the public school system of South Bend, Indiana laid off 146 teachers. All were white; 48 had more seniority than blacks not laid off; two years later 20 of the 48 had not yet been recalled. In laying off only whites, the school board was acting pursuant to a provision in its collective bargaining agreement with the teachers’ union to the effect that no blacks would be laid off until every white was laid off. The laid-off teachers sued the school system under section 1 of the Civil Rights Act of 1871, 42 U.S.C. § 1983, charging that the racially preferential layoff provision violated the equal protection clause of the Fourteenth Amendment, and seeking reinstatement and damages. The district court, after a bench trial, gave judgment for the board. 593 F.Supp. 1223 (N.D.Ind.1984). The court thought the board’s adoption of the provision a reasonable means toward the board’s goal, which the court also thought reasonable, of raising the percentage of black teachers in the South Bend school system to that of black students. The board had resolved “to increase the percentage of minorities [meaning blacks] in its teaching force until that percentage equals the percentage of minorities in its student body. The Board specifically resolved to increase the percentage of minority pupils [sic —the judge meant ‘teachers’] because it deemed it essential that the student population, both black and white, have a sufficient number of minority teachers to act as role models.” Id. at 1225. “In cases dealing with school corporations, it is proper to compare the percentage of minority faculty with the percentage of minorities in the student body rather than with the percentage of minorities in the relevant labor pool ... because of the vital role teachers play as role-models for their students. This is particularly true in the rise [sic —the judge apparently meant ‘case’] of minority teachers since ‘societal discrimination has often deprived minority children of other role models.’ ” Id. at 1230 n. 3.

The plaintiffs appealed. A divided panel of this court affirmed. 775 F.2d 794 (7th Cir.1985). The full court then granted rehearing en banc. Before the case could be reargued, the Supreme Court decided a similar case in favor of another group of white public school teachers. Wygant v. [768]*768Jackson Board of Education, 476 U.S. 267, 106 S.Ct. 1842, 90 L.Ed.2d 260 (1986). Like the panel in the present case, the Sixth Circuit had upheld the dismissal of the complaint. The Supreme Court reversed. It rejected the “role models” rationale on which the Sixth Circuit, like the district court in the present case, had based its decision. The Supreme Court did not remand for further proceedings to determine whether the plaintiffs' constitutional rights had been violated; it held they had been. When the present case was rear-gued to us, the question no longer was reversal or affirmance; it was whether to reverse outright, holding that the plaintiffs had proved a violation of their constitutional rights and remanding only for the determination of the appropriate remedy; or to remand for further proceedings in which the board would have an opportunity to establish a rationale for racially discriminatory layoffs that would be consistent with the Wygant decision.

The constitutional status of discrimination by public bodies in favor of blacks and other members of minority groups is contentious and unsettled; but with the Supreme Court having spoken so recently to a set of facts so close to those of the present case, the task for us is the interpretation of the Court’s decision rather than the forging of new constitutional law. Wygant came out of the public school system of Jackson, Michigan. In 1968, the year before the Jackson board of education adopted a racially preferential hiring plan, 4 percent of the city’s public school teachers were black, compared to 15 percent of the students. Wygant v. Jackson Board of Education, 746 F.2d 1152, 1156 (6th Cir.1984), rev’d, 476 U.S. 267, 106 S.Ct. 1842, 90 L.Ed.2d 260 (1986). Because Michigan’s civil rights commission believed that the disparity was due to discrimination against black teachers (see 106 S.Ct. at 1854), the board of education agreed to give preference in hiring to blacks until the percentage of black teachers was equal to that of black students. By 1971, 9 percent of the teachers were black. 746 F.2d at 1156. That year it became necessary to lay off some teachers. The board did this in the usual way — reverse order of seniority. A disproportionate number of those laid off were black, because so many blacks had been hired recently and therefore had little seniority. The racial situation in the Jackson public schools soon became even more tense — became, indeed, violent. See 106 S.Ct. at 1859. Expecting that additional layoffs would be necessary in the near future, the board decided it must take measures to make sure that such layoffs would not reduce the number of black teachers disproportionately. The board felt it needed to have as many black teachers as possible in order to quiet the schools and give black students role models. It also feared that the hiring of blacks would be impeded by strict adherence to the principle of laying off teachers in reverse order of seniority, because new teachers would know they would be the first to be laid off if there was a reduction in force.

In 1972 the board negotiated with the teachers’ union an agreement (which became Article XII of the collective bargaining contract with the union) to deviate from the principle of laying off teachers in reverse order of seniority, but only to the extent necessary to preserve the existing percentage of blacks (and other members of minority groups, but we can ignore that feature of the case) in the teaching force. So if 10 percent of the teachers were black, no more than 10 percent of the teachers laid off could be black.

The collective bargaining contract in Wy-gant was ratified by an overwhelming majority of the Jackson public school teachers, most of whom were white. Nevertheless, in a suit by white teachers laid off because of Article XII, the Supreme Court held that the provision was a denial of equal protection. Although there was no majority opinion in Wygant, a “lowest common denominator” majority position can be pieced together. “When a fragmented Court decides a case and no single rationale explaining the result enjoys the assent of five Justices, ‘the holding of the Court may be viewed as that position taken by those Members who concurred in the judgments on the narrowest grounds.’ ” Marks v. [769]*769United States, 430 U.S. 188, 193, 97 S.Ct. 990, 993, 51 L.Ed.2d 260 (1977).

Justice Powell, writing in Wygant for three Justices, opined that a public body may not use race as a criterion for layoffs unless necessary to protect a proven victim of discrimination, such as a black who if he had not been discriminated against would have had as much seniority as a white. See 106 S.Ct. at 1849-52. Justice White took the same position, only more bluntly. See id. at 1857-58.

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819 F.2d 766, 43 Fair Empl. Prac. Cas. (BNA) 1483, 1987 U.S. App. LEXIS 6536, 43 Empl. Prac. Dec. (CCH) 37,104, Counsel Stack Legal Research, https://law.counselstack.com/opinion/elmer-britton-v-south-bend-community-school-corporation-ca7-1987.