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Civil Rights Court Case: Griggs V. Duke Power Co Research Paper

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Updated: Apr 20th, 2019


Case laws, statutes and activities of civil rights groups, unions and the media have influenced the evolution of civil rights in the US. Decisions made by courts over the last 200 years have contributed significantly to the evolution of civil rights in the country. This research paper seeks to analyze the court decision in Griggs V. Duke Power Co, a civil rights case that involved discrimination and adverse effects on employees.

The supreme court of the United States made the decision in 1970. Arguably, prohibition of American companies from applying some requirements that discriminate employees based on qualifications and tests that do not pertain to their performance originates from this case.

Background to the case


The case involves the policy at the Duke Power Company employment policy of 1950s that allowed black people to work in the labor section of the company. Employees in this department were the least paid in the company. Sometimes in 1955, the Duke Power Company started asking employees to present their IQ test results in addition to high school diplomas (Frum 247).

After the Civil Rights Act came to play, the Duke Power Company decided to remove all its racial restrictions. However, the restriction on high school diploma was maintained (Frum 247). This initiative brought a lot of controversy because most black people did not have high school diplomas and were more likely to score low IQ scores than the white people.

Therefore, African Americans were selected at lower rates at the company compared with their white counterparts. However, analysts found that the white employees who had been working at the company and had no high school diplomas performed their jobs to the expected standards even though they had not undergone IQ tests (Frum 249).


Griggs and other employees (hereby called Griggs) sued the company, accusing it of discriminating against African-American communities. The case was brought before the Supreme Court and was heard by Justice Warren E Burger, the Chief Justice, and six other associate judges.

Law and Application

The significant statute applied in this case was the Civil Rights Act of 1964. According to the jury, section VII of the Act requires employers to demonstrate evidence of the relevance of such tests as IQ and academic qualifications to the job performance.

This section was interpreted to mean that employment tests are prohibited under the law if they are used as a decisive factor in making decisions on employment. In addition, the bench argued that the test was not a reasonable measure of the employees’ ability to perform.


The requirements to have both qualifications (High IQ scores and a high school diploma) were found to be “broad based” and not applicable to determine an employee’s level of performance at the specific job position (Greenhouse A21). The court held that these requirements were violating section seven of the statute and that it was wrong for the company to discriminate against some minority ethnic groups.

The petitioner’s lawyer, Mr. Julius Chambers, argued “…some requirements are irrelevant to certain jobs and have the effect of disqualifying some people due to their ethnicities…” (Martin A17). This argument motivated the court’s decision, thereby ruling in favor of the petitioner.

Importance of the case law in the evolution of American civil rights

The court ruling in Griggs v. Duke Power Company contributed significantly to the evolution and development of civil right laws in the United States. In particular, this case touched the issue of discrimination in employee hiring process, especially based on racial differences.

For instance, due to social and economic backgrounds, African-Americas and other minority groups had fewer chances of obtaining a high school diploma and high IQ scores compared to members of the white majority groups. In fact, the particular case involved the company’s plant in Dan River, North Carolina. Historically, this area had a long history of racial discrimination at the workplace.

Secondly, apart from racial discrimination at the workplace, it is evident that the case ruling provides guidance for companies when they seek to make decisions on employment requirements. In particular, the ruling in the case provides evidence of protection of civil rights during the employment process.

The requirement to have such tests as IQ and academic certificates should be used only when the particular job position advertised relates to the test and academic level. This ruling seems to prohibit companies from making oppressive employee requirements that do not pertain to the level of employee performance.

In addition, the judges argued that employers should provide enough evidence to show that certain tests and qualifications are necessary for employee performance at the workplace. Failure to do so, a company would be violating the provisions of The Civil Rights Act.

However, in 1991, the Supreme Court removed this burden by arguing that employers are only supposed to produce evidence of the tests within the context of business justifications. This decision was made for the ruling in Wards Cove Packing Company v. Antonio.

According to Frum (242), prior to the ruling in Griggs V Duke Power Company, the US laws did not provide employers with a line separating intentional wrongs from unintentional wrongs when treating potential employees equally by their appearances.

In addition, the case was cited in Ricci v. DeStefano case in which Justice Ginsburg argued that the conclusion in Griggs case prohibits overt discrimination as well as other practices that are unfair in their form and operation. However, this decision seems to have been overturned in Ricci v DeStefano.

The impact of the case on civil rights conflicts in the US

A number of rulings against discrimination at the workplace have been made since 1800s.Nevertheless; the decision in this particular case shows evidence of the court’s focus on internal affairs and policies in business and corporations. In this context, it is clear that this case has an impact on the silent but old practice of companies to discriminate against certain groups of people when hiring.

Specifically, there have been debates concerning the practice of using internal employment policies to target some groups of people and reduce or eliminate chances of hiring employees from other groups (Zirkel, Richardson and Goldberg 41).

For instance, some companies used academic qualifications as one of their requirements even in cases where the particular academic qualification did not relate to the performance at the specific job position. Noteworthy, statistics indicate that blacks and other minority groups have lower chances of achieving higher academic levels than whites achieve and other majority groups.

If companies, which are mainly owned and controlled by members of the majority groups, are allowed to continue with such behaviors, it is likely that most employment positions will be reserved for the majorities while leaving minorities jobless (Greenhouse A21).

In addition, companies would still be using IQ tests to discriminate against some groups of people. In fact, this practice would not only be discriminative, but would also create stigmatization and low self-esteem in people who find that they score low in IQ tests (Greenhouse A21).

In such situations, an employee who is rejected from a job position due to low IQ scores would be discouraged to attempt applying for another job position, which would lead to low self-esteem.


It is evident that performance in certain job positions does not necessarily relate to or rely on the level of education and IQ scores. For instance, the situation at Duke Power Company provides a clear example of how some job positions do not require employees to have academic qualifications or higher IQ scores.

It is evident that even white employees with neither of the two qualifications were performing in the same way as their counterparts who had both qualifications. Therefore, it is clear that the ruling in this case has contributed to the protection of civil rights by prohibiting employers from looking for unnecessary employee qualifications, which is discriminatory in both in the process and form.

Therefore, companies should not use requirements to discriminate against some employees based on their ability to perform. This regulation originates from this case law. Therefore, the case marks the origin of employee protection from discrimination based on qualification and IQ tests. Modern civil rights laws still borrow from the opinions of the jury in this case.

Works Cited

Frum, David. How We Got Here: The ’70s. New York, New York: Basic Book, 2010. Print.

Greenhouse, Linda. “Job Ruling Makes It Clear: Court Has Shifted Right”. The New York Times, 7 June 1989: A21. Print.

Martin, Douglas. “Julius Chambers, a fighter for civil rights, dies at 76”. The New York Times, 6 August 2013: A17. Print.

Zirkel, Perry, Sharon Richardson and Steven Goldberg. A digest of Supreme Court decisions affecting education. New York: Phi Delta Kappa International, 2011. Print.

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