Griggs v. Duke Power (1971 Employment Discrim.)

Duke Power's diploma and test requirements were facially neutral—containing no explicit racial classification—yet functioned to exclude Black applicants at substantially disparate rates, triggering Title VII's prohibitions under the newly established disparate impact framework. The critical question became whether the employer could demonstrate that these requirements were actually related to job performance and business necessity, rather than serving as pretexts for exclusion. The Court found that Duke Power failed to establish that the requirements measured job-related ability, particularly given that Black employees hired before the requirements were implemented performed satisfactorily, undercutting any claimed connection between the tests and actual job competence. Thus, the facially neutral practice fell afoul of Title VII because its discriminatory consequences could not be justified by legitimate business needs.