Dothard v. Rawlinson

In Dothard v. Rawlinson (1977), the U.S. Supreme Court addressed how Title VII of the Civil Rights Act of 1964, which forbids sex discrimination in the workplace, applied to a state prison's employment policies regarding prison correctional officers. At the time, Alabama had a statute that specified that prison guards must be at least five feet, two inches tall and weigh at least 120 pounds. The plaintiff in Dothard, a female applicant for a prison correctional officer position within an Alabama maximum-security facility, alleged that this policy, although seemingly neutral with regard to gender, had a discriminatory impact in practice. Namely, women were far less likely than men to meet the state's minimum physical standards. The weight and height requirements in question disqualified about 40% of female applicants, and only 1% of male applicants. The Court held that once a plaintiff demonstrates that an employment policy has a disparate impact on the basis of sex, the burden of proof then shifts to the employer, who must show that there is a manifest relationship between the specified qualifications and the employment in question. The plaintiff would then have the opportunity to demonstrate that “other selection devices without a similar discriminatory effect would also serve the employer's legitimate interest in efficient and trustworthy workmanship.”

In Dothard v. Rawlinson, the Court ruled that the plaintiff did indeed establish a prima facie case of sex discrimination and that the state did not demonstrate the validity of using height and weight standards to measure an applicant's ability to serve as a correctional officer. As a result, the minimum height and weight requirements were held to be in violation of Title VII of the Civil Rights Act of 1964. The Supreme Court thus paved the way to open up employment as correctional officers to female applicants.