Facts of the Case
Dial Corporation was an international company that manufactured canned meat. All the newly employed workers in Dial Corporation would be referred to the packaging department, where they would lift loads of meat and transport the loads across a specified distance. The constant lifting and physical transport of meat resulted in a number of work-related injury complaints. These claims were higher in the packaging department than in any other department. Therefore, the company came up with a solution, which entailed testing all applicants before hiring them in an effort to reduce work-related injuries. The test was called the Work Tolerance Screen (WTS), where the candidates would carry loads over a specified distance to see who would bear the weight. The test eliminated all who would not withstand the weight. This test seemed to favor men; more men than women passed the test due to the physical build of men. Thus, very few women were employed after the WTS test was introduced. The Equal Employment Opportunity Commission (EEOC) took Dial Corporation to court, claiming that the WTS test resulted in discrimination against women because it disadvantaged women who desired employment in the company.
Procedural History
The District Court ruled in support of the EEOC, which sued on behalf of women who had been denied employment because they could not pass the WTS. The court held that the WTS test was discriminatory against the female applicants. The court argued that Dial Corporation had not adequately shown the importance of the test to its business. The decline in injuries reported could have been caused by the other changes the company had implemented to ensure the safety of the workers. Therefore, the company failed to prove that the WTS test had caused any improvements in weight-related injuries in the company.
Key Issues
Dial Corporation brought a physiology witness, who testified that the WTS test was relevant to the business in an effort to prove that the test was not discriminative. The witness testified that the skills that were tested were appropriate for the type of work they were to do if they qualified. Moreover, the number of injuries had reduced as a result of the WTS test. The witness argued that the decrease in injuries justified the fact that the test was disadvantageous to women.
The EEOC argued its case using the Title VII of the Civil Rights Act, 1964 on sex discrimination (Brauer 38), where it claimed that it was discriminative to set a test that discriminated against women who applied for employment. The EEOC brought a witness who testified that the test was relatively harder than the actual work the employees did in the company. The Commission also presented statistics to show a decrease in the number of women employed since the introduction of the test. It argued that men and women worked together comfortably before the test was implemented.
Dial Corporation claimed that the statistics presented by EEOC were inadmissible because men and women did not have the same physical capabilities.
Legal Holding
The jury trial ruled in support of the holding of the District Court.
Rationale
An employer must show that the act they are accused of doing is beneficial to the employees. In other words, the employer must demonstrate that the practice contributes to the safety of the workers (Bird 139). In addition, the employer must show that the skills that are tested are necessary for executing the task at hand. In the instance case, the statistics revealed that the decrease in injuries reported started before the WTS test was implemented. The statistics also showed a drastic decline in the number of women employed since the introduction of the test.
Judgement
The Appellate Court ruled in support of the District Court because Dial Corporation had not proven that applying the WTS test was necessary for the safety of the employees. Moreover, the injuries would still have reduced if the company had used alternative safety measures.
Works Cited
Bird C. Robert. “More than a Congressional Joke: A Fresh Look at the Legislative History of Sex Discrimination of the 1964 Civil Rights Act.” William & Mary Journal of Women and the Law 3.1 (1997): 137-161. Print.
Brauer, M. Carl. “Women Activists, Southern Conservatives, and the Prohibition of Sex Discrimination in Title VII of the 1964 Civil Rights Act.” The Journal of Southern History 49.1 (1983): 37-56. Print.