Firefighters Local Union No. 1784 v. Stotts 467 U.S. 561 (1984)

• Author: Edward J. Erler
• Pages: 1044-1045

Page 1044

The City of Memphis, Tennessee, laid off white firefighters with more seniority to protect the positions of less senior blacks who had been employed under a "race conscious" AFFIRMATIVE ACTION plan. The white firefighters sued, alleging that their seniority rights were explicitly protected by the CIVIL RIGHTS ACT OF 1964.

Justice BYRON R. WHITE, writing for the Supreme Court's majority, agreed, noting that "mere membership in the

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disadvantaged class is insufficient to warrant a seniority award; each individual must prove that the discriminatory practice had an impact on him." White thus affirmed the proposition, which is explicit from the plain language of Title VII, that rights vest in the individual and not in the racial class, and that this fact demands a close fit between injuries and remedies. White's opinion raises some doubt about the power of courts to fashion classwide remedies where, as in race-conscious affirmative action plans, benefited individuals are not required...