City of Los Angeles Department of Water and Power v. Manhart, 435 U. S. 702, 98 S. Ct. 1370, 55 L. Ed. 2d 657, Web 1978 U. S. Lexis 23 (Supreme Court of the United States).
Issue
City of Los Angeles Department of Water and Power v. Manhart was a case involving the aforementioned company and several of its female employees, in which the employees questioned the firm’s decision to charge a higher pension fee than their male counterparts on the basis that women live longer than men do. The main issue in this case was whether the company’s pension plan was discriminatory of female workers as a class (City of Los Angeles, Department of Water and Power, et al., petitioners, v. Marie Manhart et al., n.d.).
Rule
The law applied in this case was the Equal Employment Act, which is found in the 1964 Civil Rights Act as Title VII. Under the law, it is unlawful for an employer to discriminate a worker based on the employee’s color, race, sex, religion or nationality (Civil Rights Act, 1964).
Analysis
Mr. Justice Stevens delivered the opinion of the court in which he considered the rulings made by lower courts involved in the case. Justice Stevens argued that the idea of women generally living longer than men was not contentious, adding that both parties agreed that the concept was indeed true (Los Angeles Dept. of Water and Power v. Manhart, 2013). The bigger issue in the case, therefore, revolved around the manner in which the company treated women. Using the aforementioned assumption, the company was treating male and female employees as two different classes. This practice was unfair because certain individuals from both classes fail to live up to the expectations set for them according to their class. This means that some women would fail to live as long as the average male, while some men were likely to live longer than the average woman does.
Based on the aforementioned premise, the court argued that generalizations, including accurate ones, could not be used to disqualify individuals to whom the stereotypes failed to apply (Los Angeles Dept. of Water and Power v. Manhart, 2013). Since there is no assurance that the any woman in the department would outlive her male counterparts, it can be assumed that the company’s policy was being applied to all women as a class and not as individuals. This means that the company’s policy is in direct conflict with Title VII of the 1964 Civil Rights Act. This situation outlines two different types of discrimination, class and individual. When people are treated differently because of a common characteristic that they all share, the law considers that an instance of class discrimination. Alternatively, different treatment because of a personal characteristic is an example of individual discrimination.
Justice Stevens also disagreed with the argument put forward by the company regarding the implications of Senator Humphrey’s comments during the Senatorial debate concerning the 1964 Civil Rights Act. In the debate, Senator Humphrey implied that the Act would not change the structure of existing pension plans (Los Angeles Dept. of Water and Power v. Manhart, 2013). Regardless of the implications of Senator Humphrey’s statements in the Senate, the court argued that it did not find the statements to have any large insinuations on the meaning of the subject act.
Another issue brought forward by the company regarded the restitution. The district court dealing with the case had awarded retroactive relief to all of the company’s female workers and retirees. Title VII of the Civil Rights Act does not require the court to award such restitution unless it deems it appropriate. The court ruled against the awarding of retroactive relief to female employees and retirees. Several key ideas were put forward in favor of this ruling. Firstly, the judges acknowledged that the company was not completely at fault for the unfair pension payment scheme that was in place. Accurate calculations had been made to in order to come with a scheme that was expected to compensate for the fact that women would be drawing from the pension scheme for a longer period than men did. Additionally, forcing the pension fund to refund the fees would place it in a precarious position that could have possibly seen it come under threat of instability in the future.
Conclusion
The court ruled that the company’s policy regarding different pension payments for men and women was unlawful and violated Title VII of the 1964 Civil Rights Act. On the issue of retroactive relief, the court decided that the company should not be forced to reimburse the employees for the overpaid pension fees (Los Angeles Dept. of Water and Power v. Manhart, 2013).
References
City of Los Angeles, Department of Water and Power, et al., petitioners, v. Marie Manhart et al. (n.d.). Retrieved from http://www.law.cornell.edu/supremecourt/text/435/702
Civil Rights Act of 1964, Pub. L. 88-352, 78 Stat. 241 (1964).
Los Angeles Dept. of Water and Power v. Manhart. (2013). Retrieved from http://www.leagle.com/decision/19781137435US702_11108.xml/LOS%20ANGELES%20DEPT.%20OF%20WATER%20&%20POWER%20v.%20MANHART
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