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What was the significance of the Supreme Court case Patterson v.
McLean Credit Union?
The case was initially heard by the Supreme Court in 1988, but the Court later restored it to the calendar for reargument, requesting the parties to address whether the Court's prior interpretation of Section 1981 in Runyon v.
McCrary should be reconsidered.
Section 1981 of Title 42 of the United States Code prohibits racial discrimination in the making and enforcement of private contracts, including employment contracts.
Brenda Patterson, the plaintiff, was a black woman who had worked as a teller and file coordinator at McLean Credit Union for 10 years before being laid off in 1982.
Patterson sued McLean Credit Union, alleging racial harassment and failure to promote her to a better-paying position in favor of a less-qualified white employee, in violation of Section 1981.
The key issue in the case was whether Patterson could establish a claim for racial harassment under Section 1981, and whether she was required to show that she was more qualified than the person promoted to prevail on her promotion discrimination claim.
The Supreme Court's initial ruling in 1988 requested the parties to reargue the case, focusing on whether the Court's prior interpretation of Section 1981 in Runyon v.
McCrary should be reconsidered.
In its final decision in 1989, the Supreme Court upheld the interpretation of Section 1981 adopted in Runyon v.
McCrary, but it also held that Patterson did not have to show she was better qualified than the promoted employee to prevail on her promotion discrimination claim.
The Court indicated that Patterson could instead seek to demonstrate that the employer's claim of promoting a better-qualified applicant was pretextual by showing she was in fact better qualified.
The case was remanded to the lower court for further proceedings consistent with the Supreme Court's ruling.
The Supreme Court's decision in Patterson v.
McLean Credit Union helped to clarify the scope of Section 1981's protection against racial discrimination in private employment contracts.
The case was significant in establishing that Section 1981 could be used to challenge racial harassment in the workplace, even if it did not involve the direct denial of a contractual right.
The decision in Patterson v.
McLean Credit Union laid the groundwork for later court rulings that expanded the protections of Section 1981 against racial discrimination in employment.
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