American Tobacco Company v. Patterson (1981)
- Docket
- 80-1199
- Decided
- 1981-01-01
Summary
Question: Does the section of the Civil Rights Act that affirms the legality of seniority systems apply to those adopted after the effective date of the Act? Conclusion: Yes. Justice Byron R. White delivered the opinion of the 5-4 majority. The Court held that the absence of any sort of grandfather clause or explicit distinction between pre- and post-Act systems meant that the section applied to all seniority systems, regardless of when they were put in place. There was no clear legislative history to support the distinction between pre-existing systems and those that were implemented later. The Court also held that such a reading would drastically shift national labor policy away from the balance that Congress intended the section to strike. In his dissenting opinion, Justice William J. Brennan, Jr. argued that the decision of the Court ignored the crucial distinction between the adoption of a seniority system and its application. The section’s clear use of the language of application on the part of the employer — without any mention of adoption or the union — indicated a more narrow meaning. He also argued that the legislative history showed that Congress meant the Act to have a stronger effect on systems put in place after the effective date of the Act. Justice Thurgood Marshall and Justice Harry A. Blackmun joined in the dissent. Justice John Paul Stevens wrote a dissent where he expressed that the Court misread the section as referring to seniority systems both before and after the effective date of the Act. He argued that the purpose of the section was limited to determining which of the pre-Act systems should be considered legal and which should not; the section has no bearing on any post-Act systems.