Johnson v. Santa Clara County
**Overview of Johnson v. Santa Clara County**
Johnson v. Santa Clara County is a significant Supreme Court case that addresses the intersection of gender discrimination and affirmative action in employment practices. In this case, the Transportation Agency of Santa Clara County adopted a voluntary affirmative action plan aimed at correcting gender and racial imbalances in their workforce, particularly in skilled job categories where women were underrepresented. The case arose when Paul Johnson, a male candidate, contested the promotion of Diane Joyce, a woman, despite both being equally qualified. Johnson alleged gender discrimination under Title VII of the Civil Rights Act when Joyce was selected for the promotion.
The Supreme Court ruled in favor of the county by a 6-3 vote, affirming the legality of the agency's gender preference as a means to address systemic disparities. The Court's decision highlighted that the affirmative action plan employed flexible goals rather than strict quotas and deemed gender as one of several factors in promotion decisions. Justice Brennan's majority opinion emphasized that men were still eligible for future promotions, which tempered the concern for unfair treatment. This ruling has had lasting implications for affirmative action policies in employment, despite ongoing debates about the fairness and efficacy of such measures.
Johnson v. Santa Clara County
Date: March 25, 1987
Citation: 480 U.S. 616
Issue: Affirmative action
Significance: The Supreme Court rejected a reverse discrimination claim in which a female employee was promoted over a white male employee who was judged slightly more qualified.
In United Steelworkers of America v. Weber(1979), the Supreme Court ruled that Title VII of the Civil Rights Law of 1964 did not prohibit race-conscious affirmative action to eliminate racial imbalance in traditionally segregated job categories. In 1978 the Transportation Agency of Santa Clara County adopted a voluntary plan to address gender and racial disparity in job classifications. Although women made up 76 percent of the agency’s office and clerical staff, there were no women among its skilled craft workers. In a competition for promotion to road dispatcher, both Diane Joyce and Paul Johnson were rated as well qualified, but Johnson had slightly higher scores on the exams. When Joyce was promoted, Johnson sued for gender discrimination under Title VII.
The Court rejected Johnson’s claim by a 6-3 vote. Speaking for the majority, Justice William J. Brennan, Jr., using the reasoning in the Weber precedent, held that a limited gender preference was an appropriate means to remedy the imbalance between men and women in skilled job classifications. Brennan emphasized three points: First, Santa Clara’s plan used flexible goals rather than rigid quotas; second, gender was only one factor in the promotion choice; and third, men were not completely barred from future promotions in the agency. The decision was based on Title VII rather than the Fourteenth Amendment; therefore, there was no need to discuss the standards of strict or intermediate scrutiny. In a spirited dissent, Justice Antonin Scalia argued that Title VII’s purpose was to guarantee that race and sex would not be the basis for employment determinations.
In the 1990’s there was a strong movement against the continuing use of gender and race preferences in employment. In 1997 the Court refused to consider a challenge to California’s constitutional amendment prohibiting such preferences. Nevertheless, the Johnson decision continued to be good law except in states with constitutional prohibitions against preferences.