Washington v. Davis
426 U.S. 229 (1976)
- In order to be hired as a
police officer in Washington DC, applicants had to pass a test that was
"designed to test verbal ability, vocabulary, reading, and
- Test data showed that
African-American applicants failed the test at a much higher rate than
- Two rejected African-American
applicants sued, claiming that the test was racially discriminatory and
therefore a violation of the Equal Protection Clause of the 14th Amendment.
- The US Supreme Court found
that the test was not a violation of the Equal Protection Clause.
- The US Supreme Court
acknowledged that the test did fail a disproportionate number of minority
- However, the Court found
that in addition to showing a disproportionate impact, there must also be a showing that there was a
discriminatory motive on the State
impact is not irrelevant, but it is not the sole touchstone of an
invidious racial discrimination forbidden by the Constitution."
- The Court noted that the
city was actively trying to recruit African-Americans into the police
force, and there was no evidence of a discriminatory motive.
- The basic rule illustrated by
this case is that in order to be a violation of the Equal Protection
Clause, racial discrimination by the
State must contain two elements:
- A racially disproportionate
- Discriminatory motivation on
the part of the state actor.