Constitutional Law

Personnel Administrator v. Feeney — Study Notes

Personnel Administrator v. Feeney, 442 U.S. 256 (1979)

Study notes for Personnel Administrator v. Feeney: professor notes, cold call prep, exam angles, and memory aids.

A neutral law does not violate the Equal Protection Clause if there is no intent to discriminate.
Professor Notes

In Personnel Administrator v. Feeney, the Supreme Court addressed the Equal Protection Clause of the Fourteenth Amendment in the context of a veterans' preference law. The law, while written neutrally, was found to disproportionately benefit male applicants for civil service positions, leading to a challenge from Helen Feeney, a female applicant. The Court's ruling emphasized the distinction between disparate impact and discriminatory intent, affirming that intent to discriminate is a necessary element for a violation of the Equal Protection Clause. Professors may discuss how the case set a precedent on the necessity for proving discriminatory intent rather than simply demonstrating a disparate impact.

Cold Call Prep
  1. 1What was the primary argument made by Helen Feeney in her challenge to the Massachusetts statute?
  2. 2How did the Supreme Court distinguish between discriminatory intent and impact in this case?
  3. 3What implications does this ruling have on future employment discrimination cases?
  4. 4Can you explain the significance of the Court's conclusion regarding legislative intent?
  5. 5How does this case relate to the broader context of equal protection and employment laws?
Mnemonic Device

Intent Matters: Disparate Impact Alone Does Not Equal Discrimination.

Distinguish From
CaseDistinction
Griggs v. Duke Power Co.Griggs emphasized that employment practices resulting in disparate impact must demonstrate business necessity, highlighting the difference between impact and intent.
Washington v. DavisWashington clarified that a statute's disproportionate impact is not enough without a showing that it was enacted with discriminatory intent.
Castaneda v. PickardCastaneda focused on the failure to serve the educational needs of students rather than employment, thus it dealt with different statutory applications.
Policy Arguments

For the Rule

Supporting the veterans' preference law reinforces a societal obligation to assist those who served in the military, promoting a policy of national gratitude.

Against the Rule

However, the rule can perpetuate systemic discrimination by entrenching gender inequality in public employment opportunities.

Class Discussion Points
  • Analyze the implications of distinguishing between disparate impact and intent.
  • Discuss how this case affects the interpretation of the Equal Protection Clause.
  • Evaluate the societal benefits versus disadvantages of veteran preference laws.
  • Consider how this decision aligns with or contradicts shifts in attitudes towards gender equality in the workplace.
  • Debate whether the current legal framework adequately protects against unintentional discrimination.
Exam Angle

This case typically appears on exams focusing on the Equal Protection Clause, often exploring the concepts of discriminatory intent versus disparate impact.

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