Human Resource Management 1 ELEVENTH EDITION GARY DESSLER Part 1 | Introduction Chapter 2 Equal Opportunity and the Law PowerPoint Presentation by Charlie Cook The University of West Alabama After studying this chapter, you should be able to: 1. Cite the main features of at least five employment discrimination laws. 2. Define adverse impact and explain how it is proved and what its significance is. 3. Explain and illustrate two defenses you can use in the event of discriminatory practice allegations. 4. Avoid employment discrimination problems. 5. Cite specific discriminatory personnel management practices in recruitment, selection, promotion, transfer, layoffs, and benefits. 6. Define and discuss diversity management. 2 Equal Employment Opportunity 1964–1991 Title VII of the 1964 Civil Rights Act EEOC Executive Orders Federal Agency Guidelines Pregnancy Discrimination Act of 1978 Vocational Rehabilitation Act of 1973 11246, 11375 OFCCP Equal Employment Opportunity Equal Pay Act of 1963 Age Discrimination in Employment Act of 1967 3 Griggs v. Duke Power Company Prior to the passage of the Civil Rights Act of 1964, Duke Power Company had a policy of segregating employees according to race. Specifically, at its Dan River plant, African-Americans were allowed to work only in its Labor department, which constituted the lowest-paying positions in the company. After the Civil Rights Act was passed, the company changed its policies, adding a requirement of a high school diploma or a minimum score on an IQ test for positions in areas other than the Labor department. This had the effect of eliminating a large number of African American applicants for positions outside the Labor department. http://caselaw.lp.findlaw.com/scripts/getcase.pl?court=us&vol=401&inv ol=424 4 Early Court Decisions Regarding Equal Employment Opportunity Griggs v. Duke Power Company 1 Burden of proof is on the employer. 2 Employer’s intent is irrelevant. 3 “Fair in form” practice must also be nondiscriminatory. 4 Business necessity is a defense for adverse impact. 5 Test or practice must be related to job performance. 5 Albemarle Paper Company v. Moody The plaintiffs in Moody consisted of present and former AfricanAmerican employees of Albemarle Paper Company's mill in Roanoke Rapids, North Carolina. They charged that the company's seniority system perpetuated the overt segregation that existed in the plant's departmental job assignment system prior to 2 July 1965 (the effective date of Title VII), and they sought injunctive and back pay relief. Read more: http://www.answers.com/topic/albemarle-paper-co-vmoody#ixzz1CGHFoqqN 6 Early Court Decisions Regarding Equal Employment Opportunity (cont’d) Albemarle Paper Company v. Moody If a test is used to screen candidates, then the job’s specific duties and responsibilities must be analyzed and documented. The performance standards for the job should be clear and unambiguous. Federal guidelines on validation are to be used for validating employment practices. 7 Equal Employment Opportunity 1990–91–present Money Damages Burden of Proof Compensatory Punitive Disparate Impact Civil Rights Act of 1991 Mixed Motives Desert Palace Inc. v. Costa 8 Desert Palace Inc. v. Costa Facts of the Case Catharina Costa was fired from her job as a heavy equipment operator at Desert Palace Casino. She filed a sexual discrimination lawsuit, charging that the firing was the culmination of discrimination that had occurred during her employment. Jurors during the trial were instructed by the judge to rule for Costa if they determined that sex was a motivating factor in the firing, even if other (legal) factors were present as well. The jury ruled for Costa. Desert Palace appealed, saying that the instructions incorrectly shifted the burden of proof to the defendant in the case. A three judge panel from the 11th Circuit Court of Appeals agreed, ruling for the casino, but a subsequent review of the case by all 11 judges of the 11th Circuit reversed the panel's decision. 9 Equal Employment Opportunity 1990–91–present (cont’d) AIDS Americans with Disabilities Act (ADA) of 1990 Qualified Individual Reasonable Accommodation Employer Defenses 10 Americans with Disabilities Act The ADA imposes on employers and providers of public transportation, telecommunications, and public accommodations to accommodate individuals with disabilities. Title I of the ADA prohibits employment discrimination against qualified individuals with disabilities. 11 Equal Employment Opportunity Commission (EEOC) The federal administrative agency responsible for enforcing most federal anti-discrimination laws. The EEOC is empowered to: Conduct investigations Interpret the statutes Encourage conciliation between employees and employers Bring suit to enforce the law 12 AMERICANS WITH DISABILITIES – 2005 STATS. Epileptic Speech impaired 5% 5% Mentally retarded 6% 51% 24% Developmentally disabled Paralyzed HIV infected 3% 3% 2% 2% 2% Wheelchair users Totally blind Legally blind Hearing impaired Can you guess what disability covers 51% of the population? Hearing Impaired 13 “What?” 14 Department of Fair Employment and Housing Carper/2001 California Partnership November 4, 2005 San Francisco County Superior Court Complainant Carper has severe degenerative joint disease and requested an accessible parking space and extra keys for her live-in caregiver. Respondent 2001 California Partnership denied the request for reasonable accommodation in violation of the Fair Employment and Housing Act (FEHA). After an eight day trial, the jury found the landlord liable for disability harassment and denial of a reasonable accommodation and awarded compensatory damages. Before the jury returned to deliberate on the amount of punitive damages, the parties settled the case for $1 million dollars and affirmative relief. The affirmative relief included requiring the landlord to: develop and disseminate to all residents a written policy regarding their right to receive, and the owner’s duty to provide, reasonable accommodation under the FEHA; undergo training regarding the duties of a landlord under the FEHA; post the court’s order that the landlord violated the FEHA.” 15 Employer Obligations Under ADA An employer must make a reasonable accommodation for a qualified disabled individual unless doing so would result in undue hardship. Employers are not required to lower existing performance standards or stop using tests for a job. Employers may ask pre-employment questions about essential job functions but can not make inquiries about disability. Medical exams (or testing) for current employees must be job-related. Employers should review job application forms, interview procedures, and job descriptions for illegal questions and statements. Employers should have up-to-date job descriptions that identify the current essential functions of the job. 16 Disabilities and ADA Courts will tend to define “disabilities” quite narrowly. Employers are not required to tolerate misconduct or erratic performance, even if the behaviors can be attributed to the disability. Employers do not have to create a new job for the disabled worker nor reassign that person to a lightduty position for an indefinite period, unless such a position exists. Employers should not treat employees as if they are disabled so that they will not be “regarded as” disabled and protected under the ADA. 17 18 State and Local Equal Employment Opportunity Laws State and Local Laws Cannot conflict with federal law but can extend coverage to additional protected groups. The EEOC can defer a discrimination charge to state and local agencies that have comparable jurisdiction. 19 Title VII: Sexual Harassment Sexual Harassment Harassment on the basis of sex that has the purpose or effect of substantially interfering with a person’s work performance or creating an intimidating, hostile, or offensive work environment. Employers have an affirmative duty to maintain workplaces free of sexual harassment and intimidation. Federal Violence Against Women Act of 1994 A person who commits a violent crime motivated by gender is liable to the party injured. 20 Proving Sexual Harassment Quid Pro Quo Hostile Environment Created by Supervisors Proving Sexual Harassment Hostile Environment Created by Co-Workers or Nonemployees 21 TABLE 2–2 Summary of Important Equal Employment Opportunity Actions Title VII of 1964 Civil Rights Act, as amended Executive orders Federal agency guidelines Supreme Court decisions: Griggs v. Duke Power Co., Albemarle v. Moody Equal Pay Act of 1963 Age Discrimination in Employment Act of 1967 State and local laws Vocational Rehabilitation Act of 1973 Pregnancy Discrimination Act of 1978 Vietnam Era Veterans’ Readjustment Assistance Act of 1974 Ward Cove v. Atonio Price Waterhouse v. Hopkins Americans with Disabilities Act of 1990 Civil Rights Act of 1991 Note: The actual laws (and others) can be accessed at: http://www.legal.gsa.gov/legal(#1)fcd.htm. 22 Sexual Harassment: Court Decisions Meritor Savings Bank, FSB v. Vinson Sexual Harassment Burlington Industries v. Ellerth Faragher v. City of Boca Raton 23 Lets Exam the changing of these laws Meritor Savings Bank v. Vinson Respondent former employee of petitioner bank brought an action against the bank and her supervisor at the bank, claiming that, during her employment at the bank, she had been subjected to sexual harassment by the supervisor in violation of Title VII of the Civil Rights Act of 1964, and seeking injunctive relief and damages. At the trial, the parties presented conflicting testimony about the existence of a sexual relationship between respondent and the supervisor. The District Court denied relief without resolving the conflicting testimony, holding that, if respondent and the supervisor did have a sexual relationship, it was voluntary, and had nothing to do with her continued employment at the bank, and that therefore respondent was not the victim of sexual harassment. The court then went on to hold that, since the bank was without notice, it could not be held liable for the supervisor's alleged sexual harassment. 477 U.S. 57 (1986) 25 BURLINGTON INDUSTRIES, INC. v. ELLERTH Respondent Kimberly Ellerth quit her job after 15 months as a salesperson in one of petitioner Burlington Industries’ many divisions, allegedly because she had been subjected to constant sexual harassment by one of her supervisors, Ted Slowik. Ellerth refused all of Slowik’s advances, yet suffered no tangible retaliation and was, in fact, promoted once. Moreover, she never informed anyone in authority about Slowik’s conduct, despite knowing Burlington had a policy against sexual harassment. Under Title VII, an employee who refuses the unwelcome and threatening sexual advances of a supervisor, yet suffers no adverse, tangible job consequences, may recover against the employer without showing the employer is negligent or otherwise at fault for the supervisor’s actions, but the employer may interpose an affirmative defense. The Court ruled in favor of the employee in this case. Decided June 26, 1998 26 FARAGHER v. CITY OF BOCA RATON After resigning as a lifeguard with respondent City of Boca Raton (City), petitioner Beth Ann Faragher brought an action against the City and her immediate supervisors, Bill Terry and David Silverman, for nominal damages and other relief, alleging, among other things, that the supervisors had created a "sexually hostile atmosphere" at work by repeatedly subjecting Faragher and other female lifeguards to "uninvited and offensive touching," by making lewd remarks, and by speaking of women in offensive terms, and that this conduct constituted discrimination in the "terms, conditions, and privileges" of her employment in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e-2(a)(1). Following a bench trial, the District Court concluded that the supervisors' conduct was discriminatory harassment sufficiently serious to alter the conditions of Faragher's employment and constitute an abusive working environment. Decided June 26, 1998 27 Justice Antonin Scalia “US Supreme court held that sexual harassment law doesn’t cover ordinary “intersexual flirtation.” In this ruling, Justice Antonin Scalia said courts must carefully distinguish between “simple teasing and truly abusive behavior.” Dessler, 2008 28 March 04, 2008 Court Examines Workplace Flirtation What the court said. In order to prove a hostile work environment claim, the employee had to show: (1) that she suffered intentional discrimination because of her sex, (2) the discrimination was severe or pervasive, (3) it detrimentally affected her, (4) it would have detrimentally affected a reasonable person in like circumstances, and (5) there is a basis for employer liability. The court examined the manager's behavior against this standard. http://hr.blr.com/news.aspx?id=78061 29 30 HR in Practice: What Employers Should Do to Minimize Liability in Sexual Harassment Claims 1. Take all complaints about harassment seriously. 2. Have the victim to inform the harasser directly that the conduct is unwelcome and must stop. 3. Conduct a thorough investigation of any complaint of harassment. 4. Issue a strong policy statement condemning harassing behaviors. 5. Inform all employees about the policy prohibiting sexual harassment and of their rights under the policy. 6. Communicate to employees that sexual harassment will not be tolerated. 7. Establish a management response system that includes an immediate reaction and investigation by senior management. 8. Provide training to supervisors and managers to increase their awareness of the issues. 9. Discipline managers and employees involved in sexual harassment. 10. Keep thorough records of complaints, investigations, and actions taken. 11. Conduct exit interviews that uncover any complaints. 12. Re-publish the sexual harassment policy periodically. 13. Encourage upward communication to discover evidence of sexual harassment 14. Do not retaliate against an individual for opposing employment practices that discriminate based on sex or for filing a discrimination charge, testifying, or participating in an investigation, proceeding, or litigation under Title VII. Sources: www.eeoc.gov/types/sexual_harrasment.html, accessed May 6, 2007, and © 1991by CCH Incorporated. All rights reserved. Reprinted with permission from Sexual Harassment Manual for Managers and Supervisors, published in 1991, by CCH Incorporated, a WoltersKluwer Company. 31 California State University, Fresno: Complaint Form for Filing a Complaint of Harassment or Discrimination Stacy Johnson-Klein Source: California State University, Fresno. 32 *Adverse Impact (*Against a protected group) Showing Adverse Impact Disparate Rejection Rates Restricted Policy Population Comparisons McDonnellDouglas Test 33 HR Guide to the Internet: WALKER v. SECRETARY OF TREASURY, I.R.S. | Leagle.com 34 Adverse Impact Federal agencies use a “4/5ths rule” to assess disparate rejection rates. A selection rate for any racial, ethnic, or sex group, which is less than four-fifths or 80% of the rate for the group with the highest rate, will generally be regarded as evidence of adverse impact, while a greater than four-fifths rate will generally not be regarded as evidence of adverse impact. 4/5ths = 80% or .80 Example: Suppose the employer hires 60% Caucasian and only 30% Hispanic applicants. .60 x .80 = .48 or 48% 48% is less than 30% = Variance of .18 or 18% Adverse impact exists as far as the Federal agencies are concerned. 35 Adverse Impact 4/5ths = 80% or .80 Example: Suppose the employer hires 52% Black and only 37% Hispanic applicants, 11 % other. .52 x .80= .416 or 42% 42% is less than 37% = Variance of .05 or 5% Adverse impact exists as far as the Federal agencies are concerned. Under Affirmative Action, HR would have to strengthen the number of hired Hispanic workers in order to be in compliance. Showing *Disparate Treatment (*Against a PERSON) McDonnell-Douglas Test for **Prima Facie Case 1 The person belongs to a protected class. 2 The person applied and was qualified for the job. 3 The person was rejected despite qualification. 4 The employer continued seeking applications. **Latin for "at first view." A prima-facie case is a lawsuit that alleges facts adequate to prove the underlying conduct supporting the cause of action and thereby prevail. (Blacks Law Dictionary) 37 Bona Fide Occupational Qualification Age Bona Fide Occupational Qualification (BFOQ) Religion Gender National Origin 38 Business Necessity “Business Necessity” A defense requiring employers to show that there is an overriding business purpose (i.e., “irresistible demand”) for a discriminatory practice. Spurlock v. United Airlines Validity The degree to which the test or other employment practice is related to or predicts performance on the job can serve as a business necessity defense. 39 Spurlock v. United Airlines 40 Hooters Settles Suit By Men Denied Jobs Published: October 1, 1997 Hooters has agreed to pay $3.75 million to settle a lawsuit filed by men who were denied jobs by the restaurant chain, which is known for its voluptuous and scantily clad female bartenders and servers. The settlement allows Hooters to continue luring customers with a female staff of Hooters Girls. But the chain also agreed to create a few other support jobs, like bartenders and hosts, that must be filled without regard to sex. Three men from the Chicago area sued Hooters after being denied employment at an Orland Park, Ill., restaurant. Each of them will get $19,100. Four men who filed a similar lawsuit in Maryland will receive $10,350 each. http://query.nytimes.com/gst/fullpage.html?res=9904E6DA1E3AF932A35753C1A961958260 41 Hooters Unable to Justify BFOQ over uniform disputes…. Settles Any wonder? 42 DISCRIMINATORY EMPLOYMENT PRACTICES AND THE EEOC Other Considerations in Discriminatory Practice Defenses 1. Good intentions are no excuse. 2. Employers cannot hide behind collective bargaining agreements—equal opportunity laws override union contract agreements. 3. Firms should react by agreeing to eliminate an illegal practice and (when required) by compensating the people discriminated against. 44 Discriminatory Employment Practices Recruitment Selection Personal Appearance Word of Mouth Unnecessary Educational Requirements Dress Attire - (If not necessary to the position) Misleading Information Help Wanted Ads that have discriminatory type language, attractive, young, etc. Unfair Testing/Requirements Preference to Relatives (Nepotism) Hair (Color preference, length etc.) Uniforms- (Hooters) Height, Weight, and Physical Characteristics (Not BFOQ or Business Necessity) Arrest Records (Not BFOQ or Business Necessity) Application FormsDischarge Due to Garnishment 45 The EEOC Enforcement Process EEOC Claim and Enforcement Process 1 File Charge 2 Charge Acceptance 3 Serve Notice 4 Investigation/Fact-Finding 5 Cause/No Cause 6 Conciliation 7 Notice to Sue 46 FIGURE 2–4 The EEOC ChargeApplicant or employee files charge Filing Process EEOC advises employer of charge and if mediation is an option Unsuccessful mediation EEOC may ask employer to submit statement of position of employer’s side of story Finds no reasonable cause Successful mediation EEOC may ask employer to respond to request for information (personnel files, etc.) EEOC completes investigation Issues charging party Dismissal and Notice of Rights EEOC may ask employer to permit onsite visit by EEOC and to provide information for witness interview Finds reasonable cause Issues Letter of Determination Offers parties conciliation Charging party may file lawsuit in Federal Court within 90 days Conciliation fails EEOC may litigate in Federal Court within 180 days of charge Conciliation successful EEOC may decide not to litigate Sends charging party notice of Right to Sue Party may sue within 90 days Note: Parties may settle at any time. Source: Based on information at www.eeoc.gov. 47 Questions to Ask When an Employer Receives Notice That EEOC Has Filed a Bias Claim 1. Exactly what is the charge and is your company covered by the relevant statutes? 2. What protected group does the employee belong to? Is the EEOC claiming disparate impact or disparate treatment? 3. Are there any obvious bases upon which you can challenge and/or rebut the claim? 4. If it is a sexual harassment claim, are there offensive comments, calendars, posters, screensavers, and so on, on display in the company? 5. Who are the supervisors who actually took the allegedly discriminatory actions and how effective will they be as potential witnesses? Sources: Fair Employment Practices Summary of Latest Developments, January 7, 1983, p. 3, Bureau of National Affairs, Inc. (800-372-1033); Kenneth Sovereign, Personnel Law (Upper Saddle River, NJ: Prentice Hall, 1999), pp. 36–37; “EEOC Investigations—What an Employer Should Know,” Equal Employment Opportunity Commission (http://www.eoc.gov/employers/investigations.html), accessed May 6, 2007. 48 MANDATORY ARBITRATION 49 Mandatory Arbitration Gilmer v. Interstate/Johnson Lane Corp. Employers can compel employees to agree to mandatory arbitration of employment-related disputes. Recommendations Request party be compelled to arbitrate claim. Insert arbitration clause in employment applications and employee handbooks. Protect arbitration process from appeal. Alternative Dispute Resolution (ADR) 50 Gilmer v. Interstate/Johnson Lane Corp 51 Addressing EEOC Claims During the EEOC Investigation: 1 Follow Three Principles 2 Meet with the Employee 3 Limits of EEOC Authority 4 Submitting Documents 5 Position Statement 52 Addressing EEOC Claims (cont’d) During the FactFinding Conference: During EEOC Determination and Attempted Conciliation: 1 Official Records 1 Review Carefully 2 Employer’s Attorney 2 Conciliate Prudently 3 Information 4 Witnesses 53 Diversity Management Program Steps in a Diversity Management Program: 1 Provide strong leadership 2 Assess the situation 3 Provide diversity training and education 4 Change culture and management systems 5 Evaluate the diversity management program 54 Is the Diversity Initiative Effective? Are there women and minorities reporting directly to senior managers? Do women and minorities have a fair share of job assignments that are stepping stones to successful careers in the company? Do women and minorities have equal access to international assignments? Are female and minority candidates in the company’s career development pipeline? Are turnover rates for female and minority managers the same or lower than those for white male managers? 55 Designing an Affirmative Action Program Good Faith Effort Strategy Eliminating the present effects of past practices that excluded or underutilized protected groups. Identification through numerical analysis. Proactive elimination of employment barriers. Increased minority or female applicant flow. Increasing Employee Support for Affirmative Action Transparent selection procedures Communication Justifications 56 Steps in an Affirmative Action Program – 1. Issues a written equal employment policy. 2. Appoints a top official to direct and implement the program. 3. Publicizes the equal employment policy and affirmative action commitment. 4. Surveys minority and female employment to determine where affirmative action programs are especially desirable. 5. Develops goals and timetables to improve utilization of minorities, males, and females. 6. Develops and implements specific programs to achieve these goals. 7. Establishes an audit and reporting system to monitor and evaluate progress of the program. 8. Develops support for the affirmative action program, both inside the company and in the community. 57 REVERSE DISCRIMINATION Discrimination against non-minority applicants and employees by quotabased systems. 58 Reverse Discrimination Reverse Discrimination Discrimination against non-minority applicants and employees by quota-based systems. Bakke v. Regents of the University of California Wygant v. Jackson Board of Education U.S. v. Paradise Johnson v. Transportation Agency, Santa Clara County 59 60 Bakke v. Regents of the University of California http://www.oyez.org/cases/197 61 0-1979/1977/1977_76_811 62 Wygant v. Jackson Board of Education US Supreme Court Ruling… 63 U.S. v. Paradise 64 Johnson v. Transportation Agency, Santa Clara County 65 KEY TERMS Title VII of the 1964 Civil Rights Act Equal Employment Opportunity Commission (EEOC) affirmative action Office of Federal Contract Compliance Programs (OFCCP) Equal Pay Act of 1963 Age Discrimination in Employment Act of 1967 (ADEA) Vocational Rehabilitation Act of 1973 Vietnam Era Veterans’ Readjustment Act of 1974 Pregnancy Discrimination Act (PDA) uniform guidelines sexual harassment Federal Violence Against Women Act of 1994 protected class Civil Rights Act of 1991 (CRA 1991) mixed motive case Americans with Disabilities Act (ADA) qualified individuals adverse impact disparate rejection rates restricted policy bona fide occupational qualification (BFOQ) alternative dispute resolution or ADR program good faith effort strategy reverse discrimination 66