Wygant v. Jackson Board of Education (1985)
- Docket
- 84-1340
- Decided
- 1985-01-01
Summary
Question: Did the collective bargaining agreement provision for race-based layoffs violate the Fourteenth Amendment's Equal Protection Clause? Conclusion: Yes. In a 5-to-4 decision, the Court argued that Wygant's layoff stemmed from race and, therefore, violated the Equal Protection Clause. The Court noted that the government, when embarking on affirmative action, had two duties: first, to justify racial classification with a compelling state interest and second, to demonstrate that its chosen means were narrowly tailored to its purpose. Regarding the first, the Court rejected the lower court's argument that racial preferences were justified because the percentage of minority students exceeded the percentage of minority teachers. At best, this argument implied a separate but equal system, which the Court rejected in Brown v. Board of Education. Instead, racial preferences had to be based on prior discrimination. Second, the Court rejected the school's discrimination remedy: layoff preferences incorrectly addressed injurious prior discriminatory hiring practices since "denial of a future employment opportunity [was] not as intrusive as loss of an existing job."