Parson v. Kaiser Aluminum & Chemical Corp.

575 F.2d 1374, 17 Fair Empl. Prac. Cas. (BNA) 1272, 1978 U.S. App. LEXIS 10251, 17 Empl. Prac. Dec. (CCH) 8427
CourtCourt of Appeals for the Fifth Circuit
DecidedJuly 10, 1978
DocketNo. 74-3468
StatusPublished
Cited by96 cases

This text of 575 F.2d 1374 (Parson v. Kaiser Aluminum & Chemical Corp.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Parson v. Kaiser Aluminum & Chemical Corp., 575 F.2d 1374, 17 Fair Empl. Prac. Cas. (BNA) 1272, 1978 U.S. App. LEXIS 10251, 17 Empl. Prac. Dec. (CCH) 8427 (5th Cir. 1978).

Opinion

JOHN R. BROWN, Chief Judge:

Plaintiff, a black employee at the Chal-mette, Louisiana plant of Kaiser Aluminum [1377]*1377and Chemical Corporation (Kaiser), appeals from a judgment dismissing his individual and class claims of racial discrimination in employment. Finding errors of both fact and law in the dismissal at the close of the plaintiff’s case, we reverse and remand.

I.

In July 1966, the named plaintiff, Harris Parson, filed a charge with the Equal Employment Opportunity Commission (EEOC) under section 706(e) of the Civil Rights Act of 1964, 42 U.S.C. § 2000e-5(e), claiming that Kaiser discriminated against him on the basis of his race in refusing to promote him to the position of foreman. Parson also alleged that Kaiser maintained racially segregated facilities and that, with the cooperation of the employees’ bargaining representative, Local 225 of the Aluminum Workers International Union (Local 225),1 denied black employees equal opportunities for advancement. The EEOC found reasonable cause to believe that Kaiser and Local 225 engaged in discriminatory practices and, after attempting a cure by conciliation, issued Parson a right to sue notice in August 1967.

All persons within the jurisdiction of the United States shall have the same right in every State and Territory to make and enforce contracts, to sue, be parties, give evidence, and to the full and equal benefit of all laws and proceedings for the security of persons and property as is enjoyed by white citizens, and shall be subject to like punishment, pains, penalties, taxes, licenses, and exactions of every kind, and to no other.

Parson brought suit in September 1967, seeking relief against Kaiser under the Civil Rights Act of 1866, 42 U.S.C. § 1981,2 and Title VII of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000e et seq.,3 and against the [1378]*1378Union for violations of Title VII and of the duty of fair representation imposed by 29 U.S.C. §§ 151 et seq. Another black employee, Arcell Williams, joined Parson in the suit, claiming that he had been discriminatorily discharged. Parson and Williams subsequently amended their complaint to include allegations of discriminatory employment practices against a class of black hourly employees.4 After extensive and prolonged pretrial proceedings, the case came to trial in 1973. At the conclusion of the plaintiffs’ case, the defendants moved under F.R.Civ.P. 41(b) for an involuntary dismissal on the ground that “plaintiffs have shown no right to relief” on either their individual or class claims. The District Court recessed the trial, dismissed Williams’ claim and, in May 1974, some fourteen months later, dismissed Parson’s individual suit and the class action.5 In its findings of fact and conclusions of law issued under F.R.Civ.P. 52(b), the District Court held that no discrimination was present in any of the actions or practices asserted by the plaintiffs. Parson appeals on behalf of himself and the class he represents from the judgment in favor of the defendants.

Although the complaint alleged a variety of discriminatory practices,6 the appeal is limited to the following findings and conclusions: defendant Kaiser did not discriminate against Parson by refusing to award him the promotion he sought; Kaiser did not discriminate against the class in making promotions to supervisory positions; Kaiser did not discriminate in providing training and opportunities for entry to craft positions; and Kaiser and the Union did not discriminate in the contractual procedures governing bidding and transfers.

We hold that as to each of these issues, the District Court erred in holding that no discrimination was evidenced and in dismissing the suit. We reverse and remand for further proceedings consistent with the standards developed in this Circuit and the Supreme Court for judging claims of racial discrimination in employment.

II. The Challenged Employment Practices

Kaiser is engaged in the production of aluminum from powered alumina at the Chalmette facilities. At the time of trial, the plant employed over 2,400 people, of whom approximately 20 percent were black. Kaiser has operated the Chalmette plant since 1951. At that time, blacks were hired only as laborers and the physical facilities of the plant were rigidly segregated.7 Plaintiff’s essential claim at trial and on this appeal is that insufficient progress has been made since then to satisfy the requirements of the civil rights statutes.8

[1379]*1379 A. Promotions to the Position of Foreman

The plaintiff presented evidence tracing the evolution of the procedures for selecting foremen from the hourly employees.9 Until April 1966, Kaiser had no written procedures or standards governing such promotions. At that time, Kaiser adopted-a system requiring each shift foreman to evaluate the hourly employees under his supervision every six months and report the names of likely candidates. Those listed would be further screened by the general foremen and departmental superintendents, and if approved, would be administered two personnel tests, the Wonderlic Test and the How to Supervise Test. The candidates achieving sufficiently high scores would then be classified as “trainee foremen,” a status that allowed them to replace absent permanent foremen and, depending on their success, to advance to a permanent position as openings occurred. Parson’s application for promotion was considered one month after this procedure had been adopted.

This system for considering applicants was modified in June of 1967 to ameliorate the requirement that an hourly employee could not become a candidate for a supervisory position without his immediate foreman’s recommendation. The revised procedure required each foreman to submit the names of those employees who had indicated a wish to be promoted, “but whom the Foreman believes do not have the qualifications.” An applicant not approved by either his shift foreman or the department superintendent was further reviewed by a committee authorized to reverse the previous decisions and allow the employee to take the personnel tests.

The following year, Kaiser’s program was revised, apparently to reflect and anticipate changes in the law of employment discrimination. The use of the Wonderlic Test for identifying qualified condidates was eliminated after a validation study designed to relate the tests to the demands of the job failed.10 In 1970, Kaiser further revised the selection methods by instituting a procedure for selecting permanent foremen. This procedure was based on annual evaluations and recommendations from immediate supervisors subject to review by general foremen and department superintendents.

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Bluebook (online)
575 F.2d 1374, 17 Fair Empl. Prac. Cas. (BNA) 1272, 1978 U.S. App. LEXIS 10251, 17 Empl. Prac. Dec. (CCH) 8427, Counsel Stack Legal Research, https://law.counselstack.com/opinion/parson-v-kaiser-aluminum-chemical-corp-ca5-1978.