Case: Association of Mexican-American Educators v. State of California
3:92-cv-03874 | U.S. District Court for the Northern District of California
Filed Date: Sept. 23, 1992
Closed Date: Jan. 25, 2002
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Case Summary
This case concerns the legality of a California test to certify public school teachers. On September 23, 1992, two teachers’ associations and fifteen individual teachers and administrators brought this putative class action lawsuit against the State of California and the California Commission on Teacher Credentialing (“CTC”) in the U.S. District Court for the Northern District of California. The plaintiffs challenged the defendants’ use of the California Basic Educational Skills Test (“CBEST”), a requirement to become a public school teacher or administrator in California. Represented by Public Advocates, the plaintiffs alleged that the CBEST violated Titles VI and VII of the Civil Rights Act of 1964 by discriminating on the basis of race to determine employment for a federally funded program. Specifically, the plaintiffs contended that the CBEST had a disparate impact on people of color—Black, Latino, and Asian applicants failed the CBEST at significantly higher rates than white applicants. The plaintiffs also contended that the CBEST did not sufficiently relate to relevant job skills, and thus less discriminatory means existed to certify public school employees. They sought class certification, injunctive relief, and attorneys’ fees and costs under 42 U.S.C. § 1988.
On November 16, 1992, the plaintiffs filed an amended complaint to add the Oakland Alliance of Black Educators and four individual teachers as plaintiffs.
On April 1, 1993, the State of California and the CTC moved for partial summary judgment on the Title VI claims. The plaintiffs moved for partial summary judgment on the applicability of Title VII and Title VI on April 1 and May 3, 1993, respectively. The defendants also moved for partial summary judgment on the applicability of the Title VII claims on May 3.
District Judge William H. Orrick granted the plaintiffs’ motion for partial summary judgment and denied the defendants’ motion on August 25, 1993. Judge Orrick found that Title VI and VII both applied to the plaintiffs’ allegations. 836 F. Supp. 1534. The court held that the text of 42 U.S.C. § 2000d-7 allowed a state and other entities within the state public school system to be defendants in a Title VI action.
On October 13, 1993, the plaintiffs moved to certify a class of “Latino, African American, and Asian California public school credential or job applicants past, present, and future who have been or will be denied credentials or certificated positions based on the California Basic Educational Skills Test.”
The defendants moved for partial summary judgment on May 14, 1994.
On July 19, 1994, the court granted class certification and denied the defendants’ motion for partial summary judgment.
The defendants moved to compel joinder of necessary parties on April 7, 1995, which the court denied on November 7. The defendants also moved for summary judgment on July 5, 1995. One day later, the plaintiffs moved for partial summary judgment on the CBEST’s adverse impact and lack of validity.
The court denied the plaintiffs’ motion for partial summary judgment on August 9, 1995, finding that attorneys raised many genuine issues of material fact during oral argument. Judge Orrick also denied the defendants’ July 5 motion for summary judgment on August 25, 1995, holding that the doctrine of laches did not completely bar the plaintiffs’ action.
Judge Orrick presided over a trial throughout June 1996, during which the CTC moved for judgment as a matter of law on June 17.
Judge Orrick issued a judgment for the defendants on September 17, 1996, holding that the CBEST did not violate Title VI or Title VII. The court found that (1) that the plaintiffs had established a prima facie case by showing that the CBEST had a disparate impact on minorities; (2) that all three studies of the CBEST submitted to the court proved it to be a valid measure of job-related skills; (3) that the passing score reflected professionally reasonable judgments about minimum levels of basic knowledge, skills and abilities for teaching jobs; and (4) that the plaintiffs had failed to show the existence of an equally effective alternate screening device. 937 F. Supp. 1397.
On October 16, 1996, the plaintiffs appealed the district court’s decision to the United States Court of Appeals for the Ninth Circuit. The plaintiffs argued that (1) the district court erred in concluding that the CBEST was properly validated, and (2) the court violated Federal Rule of Evidence 706 by relying on the advice of an expert who was not subject to cross-examination and did not prepare a report. On October 25, 1996, the defendants filed a cross-appeal regarding the district court’s conclusions, on summary judgment, that Titles VI and VII applied. The defendants also appealed the district court’s order denying costs.
Ninth Circuit Judge Andrew J. Kleinfeld and District Judge Steven V. Judge Wilson found on July 12, 1999, that neither Title VI nor VII applied to CBEST in this case, and that the district court did not commit any reversible error in factual findings. 195 F.3d 465. Circuit Judge Robert Boochever dissented, contending that the majority’s holding relied on the mistaken conclusion that Title VII did not apply to the CBEST simply because it was a licensing exam.
The plaintiffs filed a petition for rehearing en banc on August 2, 1999, which the Ninth Circuit granted on January 21, 2000.
On June 2, 2000, the United States and the Equal Employment Opportunity Commission submitted an amicus brief, arguing that the CBEST was subject to judicial review under Titles VI and VII of the Civil Rights Act of 1964.
On June 20, 2000, the Ninth Circuit reheard the appeal en banc. Circuit Judges Procter Hug, Jr., Mary M. Schroeder, Stephen Reinhardt, Diarmuid F. O’Scannlain, Ferdinand F. Fernandez, Pamela Ann Rymer, Andrew J. Kleinfeld, A. Wallace Tashima, Sidney R. Thomas, Susan P. Graber, and Ronald M. Gould presided over the appeal. 231 F.3d. 572.
The Ninth Circuit affirmed both the judgment for the defendants and the order denying the defendants’ costs on October 30, 2000. Judge Graber held that (1) Title VII applied to the CBEST, (2) the CBEST was properly validated, (3) the district court permissibly used a technical advisor, and (4) the district court did not abuse its discretion by refusing to award costs to the defendants. Circuit Judges Reinhardt, Schroeder, Thomas, Fernandez, Rymer, Kleinfeld, O’Scannlain, and Gould concurred in part and dissented in part. Circuit Judge Tashima dissented.
The Ninth Circuit issued a mandate on December 29, 2000. The case is now closed.
Summary Authors
Sophia Acker (12/10/2023)
People
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/10229482/parties/association-of-mexic-v-state-of-california/
Fernandez, Ferdinand Francis (California)
Affeldt, John T. (California)
Goldstein, Barry L (California)
Ashe, R. Lawrence Jr. (Georgia)
Dimsey, Dennis J. (District of Columbia)
Documents in the Clearinghouse
Docket
See docket on RECAP: https://www.courtlistener.com/docket/10229482/association-of-mexic-v-state-of-california/
Last updated July 22, 2026, 5:19 a.m.
Docket for: Association of Mexic v. State of California
Case Details
State / Territory:
Case Type(s):
Key Dates
Filing Date: Sept. 23, 1992
Closing Date: Jan. 25, 2002
Case Ongoing: No
Plaintiffs
Plaintiff Description:
Three educators' associations, their members, and fifteen individual educators suing on behalf of Latino, African American, and Asian California public school credential or job applicants past, present, and future who have been or will be denied credentials or certificated positions based on the California Basic Educational Skills Test.
Plaintiff Type(s):
Non-profit NON-religious organization
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: Yes
Class Action Outcome: Granted
Defendants
State
State of California
Defendant Type(s):
Case Details
Causes of Action:
Title VI, Civil Rights Act of 1964, 42 U.S.C. § 2000d et seq.
Title VII (including PDA), 42 U.S.C. § 2000e
Other Dockets:
Northern District of California 3:92-cv-03874
U.S. Court of Appeals for the Ninth Circuit 96-17131
U.S. Court of Appeals for the Ninth Circuit 96-17133
U.S. Court of Appeals for the Ninth Circuit 97-15422
Available Documents:
Outcome
Prevailing Party: Defendant
Relief Granted:
Source of Relief:
Issues
General/Misc.:
Discrimination Area:
Discrimination Basis:
Affected National Origin/Ethnicity(s):
Affected Race(s):
Case Summary of Association of Mexican-American Educators v. State of California, Civil Rights Litig. Clearinghouse, https://clearinghouse.net/case/10826/ (last updated 12/10/2023).