Patterson v. McLean Credit Union
- Decided
- June 15, 1989
- Docket
- 87-107
- Status
- Published
- Jurisdiction
- Federal
Cited 2,518 timesOverruled (verified)Overruled (verified) · Doe v. Board of County Commissioners
What later courts said
- holding that racial harassment was an adverse employment action since it affected a “term, condition, or privilege of employment” — Walker v. Washington Metropolitan Area Transit Authority (2000)
- deciding that burden-shifting scheme developed under Title VII “should apply to claims of racial discrimination under § 1981” — Pacheco v. New York Presbyterian Hospital (2009)
- concluding that the pre-amendment Section 1981 did not cover “postformation conduct ... implicating] the performance of established contract obligations and the conditions of continuing employment.” — Graves v. District of Columbia (2011)
Each line is a later court’s own words about this case, not a summary. Read the opinion before relying on it.
How the opinion begins
[*168] Justice Kennedy delivered the opinion of the Court.
In this case, we consider important issues respecting the meaning and coverage of one of our oldest civil rights statutes, 42 U. S. C. § 1981.
[*169] Petitioner Brenda Patterson, a black woman, was employed by respondent McLean Credit Union as a teller and a file coordinator, commencing in May 1972. In July 1982, she was laid off. After the termination, petitioner commenced this action in the United States District Court for the Middle District of North Carolina. She alleged that respondent, in violation of 14 Stat. 27, 42 U. S. C. § 1981, had harassed her, failed to promote her to an intermediate accounting clerk position, and then discharged her, all because of her race. Petitioner also claimed this conduct amounted to an intentional infliction of emotional distress, actionable under North Carolina tort law.
Statutes cited
Cite this
Patterson v. McLean Credit Union, 491 U.S. 164 (1989)Read the full opinion
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