Case: Bazemore v. Friday

[This summary is temporary while we research the case.] This is a lawsuit in which African-American employees alleged that the North Carolina Agricultural Extension Service, a public agency providing agricultural education and services, engaged in racially discriminatory practices, specifically relating to salaries and the selection of County Extension Chairmen. The agency had previously operated separate programs for black and white employees; after integrating the programs, it continued to pay black employees less than their white counterparts.

The case was filed in 1971, in the U.S. District Court for the Eastern District of North Carolina. Both the district court and the Fourth Circuit Court of Appeals ruled in favor of the defendant, stating that the plaintiffs had failed to prove that salary disparities were due to racial discrimination. In a unanimous decision by Justice Brennan, the Supreme Court reversed. The Court held that regression analysis does not need to include every conceivable variable to be admissible as evidence of discrimination. The plaintiffs met their burden of proof by showing a significant disparity in pay between black and white employees, and the defendant had failed to provide a non-discriminatory explanation for this disparity.  478 U.S. 385 (1986).