Sheet Metal Workers v. EEOC: Title VII Remedies Explained

Introduction: The Judiciary and Legislative Intent

One of the primary functions of the judiciary is to clearly define the parameters of legislative intent, as the passage of any law necessarily creates parties with a vested interest in bypassing or overturning the statute. In the case of Local 28, Sheet Metal Workers v. EEOC, 478 U.S. 421 (1986), the Supreme Court was again tasked with assessing the validity of a law through its method of application. This case presented the high court with an opportunity to decisively delineate the remedies available to correct violations of Title VII of the Civil Rights Act of 1964, which prohibited employers from discriminating on the basis of race, color, religion, sex, or national origin.

When the New York State Commission for Human Rights identified New York City's Local 28 Joint Apprenticeship Committee (JAC) as a gross violator of Title VII in its hiring practices and filed suit to obtain injunctive relief, the Second Circuit Court ruled in their favor, ordering the JAC to cease and desist its racially discriminatory practices (1976). The Second Circuit Court determined that the "Sheet Metal Workers … had formally excluded Negroes until 1946, and for the next twenty years no Negro became a member of the Local 28 in New York City" (Moreno, 1999), with unofficial exclusion being maintained through an apprenticeship system defined by nepotism and bigotry.

Background of Local 28's Discriminatory Practices

Despite the Second Circuit's decision, countless rounds of litigation followed over the next eighteen years, as Local 28 and its JAC obstinately refused to adhere to the equal hiring practices mandated by Title VII. When the Supreme Court finally heard the case in 1986, the JAC's appeal of the remedies ordered by the Second Circuit targeted section 706(g) of Title VII, which "invests broad equitable discretion in the federal courts to effectuate the 'make whole' objective of Title VII [and] aims to make the victims of unlawful discrimination whole by restoring them so far as possible … to a position where they would have been were it not for the unlawful discrimination" (Napolitano, 1987).

According to the JAC's interpretation of the statutory language, "section 706(g) authorizes a district court to award preferential treatment only to actual victims of unlawful discrimination" (Brennan, 1986), despite the fact that the court had previously ruled in Griggs v. Duke Power Co. that the ostensible legal intention of Title VII was "to remove barriers that have operated in the past to favor an identifiable group of white employees over other employees" (1971).

The Supreme Court's Ruling on Section 706(g)

In deciding "whether the remedial provisions of Title VII … empower a district court to order race-conscious relief that may benefit individuals who are not identified victims of unlawful discrimination" (Napolitano, 1987), the court's contentious 5-4 decision ultimately affirmed the Second Circuit's original imposition of a 29% nonwhite membership quota and the $150,000 fine intended to provide funding for increased quality efforts within Local 28's JAC program.

The decision rendered in Sheet Metal Workers v. EEOC effectively ruled that, when devising the language of Title VII and section 706(g), "Congress did not intend to preclude nonvictims from benefiting from race-conscious relief … [as] 706(g) remedies should not be limited solely to the actual victims of discrimination" (Napolitano, 1987). The Supreme Court determined by the slimmest of margins that Title VII's enforcement provisions, as elucidated in section 706(g), permitted district courts to include individuals who may not have been directly affected by discrimination in their remedies.