Facts: Dianne Rawlinson sought employment with the Alabama Board of Corrections as a prison guard. After her application was rejected, she brought this class suit under Title VII of the Civil Rights Act of 1964.
Issues: 1. She was refused employment because she failed to meet the minimum 120-pound weight requirement and height minimum of 5 feet 2 inches. 2. Whether a rule expressly prohibiting women from assuming close-contact prison guard positions in maximum-security prisons most of which were all male violated Title VII.
Rule of Law: Title VII of the Civil Rights Act of 1964 (Pub. L. 88-352) (Title VII), as amended, as it appears in volume 42 of the United States Code, beginning at section 2000e. Title VII prohibits employment discrimination ...view middle of the document...
An Act to enforce the constitutional right to vote, to confer jurisdiction upon the district courts of the United States to provide injunctive relief against discrimination in public accommodations, to authorize the attorney General to institute suits to protect constitutional rights in public facilities and public education, to extend the Commission on Civil Rights, to prevent discrimination in federally assisted programs, to establish a Commission on Equal Employment Opportunity, and for other purposes. Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled, That this Act may be cited as the “Civil Rights Act of 1964”.
Analysis: At the time of her application, Rawlinson failed to meet the height and weight requirement of the Board of Corrections. Rawlinson viewed the rejection as an act of discrimination and a violation of the Equal Protection Clause. The Supreme Court ruled that she was discriminated based upon the height and weight requirement, but not through the Bona Fide Occupational Qualification (BFOQ), a legal way to discriminate, for a contact position. However, the BFOQ disqualified Rawlinson as a female because she was a liability risk. This is due to the fact that women are viewed as less authoritative and weaker.
Conclusion: The three panel District court found for Rawlinson on both counts of discrimination. The Supreme Court, however, upheld on the basis of the height and weight discrimination but found that the District Panel was incorrect in finding the statue violated Title VII because of gender based criteria. I agree with the Supreme Court that women would be at a greater risk then a man, if the prisoners decided to rebel against the guards.