Petitioners
Saint Francis College et al.
Respondent
Majid Ghaidan Al-Khazraji, etc.
Petitioners' Claim
That a section of the U.S. Code barring racial discrimination did not apply to persons of Arab ancestry.
Chief Lawyer for Petitioners
Nick S. Fisfis
Chief Lawyer for Respondent
Caroline Mitchell
Justices for the Court
Harry A. Blackmun, William J. Brennan, Jr., Thurgood Marshall, Sandra Day O'Connor, Lewis F. Powell, Jr., William H. Rehnquist, Antonin Scalia, John PaulStevens, Byron R. White (writing for the Court)
Justices Dissenting
None
Place
Washington, D.C.
Date of Decision
18 May 1987
Decision
Affirmed the decision of the U.S. Court of Appeals and granted the respondentthe right to state his claim of racial discrimination against St. Francis College.
Significance
The Supreme Court's decision in Saint Francis College v. Al-Khazraji clarified the criteria for making a racial discrimination claim under section1981 of the U.S. Code.
The Facts of the Case
Professor Majid Ghaidan Al-Khazraji, a U.S. citizen born in Iraq, served on the faculty of St. Francis College in Pennsylvania. In January of 1978, he applied for academic tenure, but the college's board of trustees denied his request. Al-Khazraji later left the school's employ and filed complaints with thePennsylvania Human Relations Commission and the Equal Employment Opportunities Commission (EEOC). Upon advice from the EEOC, Al-Khazraji filed suit in U.S. District Court in 1980, claiming his tenure had been denied on the basis of race, in violation of the U.S. Code.
The Lower Courts Rule
The U.S. District Court first had to determine whether the statute of limitations had expired on Al-Khazraji's right to sue. It held that six-year limitation applied to this case and that Al-Khazraji, therefore, had a right to bring his action in court. The district court then proceeded to the question of Al-Khazraji's right to sue based on racial discrimination. The issue was whether an Arab, classified as a Caucasian under commonly accepted racial criteria, could charge racial discrimination under the U.S. Code. At first, the courtsided with Al-Khazraji and ruled that he could, but when St. Francis Collegemoved for summary judgement before a different judge, the court ruled in itsfavor. The second judge interpreted Al-Khazraji's complaint asserting only discrimination on the basis of national origin and religion, not race. Al-Khazraji then appealed this decision to the U.S. Court of Appeals for the Third Circuit.
The court of appeals reversed the district court's ruling on the merits of the case. It also applied the statute of limitations and ruled that Al-Khazrajihad filed his suit in a timely manner. It reasoned that while under currentracial classifications Arabs are Caucasians, Al-Khazraji could file a discrimination complaint because Congress had intended to protect all members of anygroup "that is ethnically and physiognomically distinctive." St. Francis College then appealed this decision to the U.S. Supreme Court.
The Supreme Court Affirms
On 18 May 1987, the Supreme Court ruled on the case. In a unanimous decision,the Court affirmed the ruling of the court of appeals and allowed Al-Khazraji to proceed with his complaint. As had two previous courts before it, the Supreme Court first established that there was no "time bar" to Al-Khazraji's complaint, since the six-year statute of limitations applied in this instance.It then moved on to the merits of the case.
In his majority opinion, Justice White made three key determinations. First,he concurred with the ruling of the court of appeals that held that Congresshad intended for its anti-discrimination legislation to encompass even thosecitizens who would be considered Caucasian under commonly accepted racial classification guidelines. After outlining the history and usage of the term "race" in Western culture, White concluded: "We have little trouble in concluding that Congress intended to protect from discrimination identifiable classesof persons who are subjected to intentional discrimination solely because oftheir ancestry or ethnic characteristics."
Next, White addressed the question of whether persons attempting to claim racial discrimination under Section 1981 must exhibit physical characteristics that single them out for identification--and by extension prejudice. To White,such visible differences were not necessary. "[A] distinctive physiognomy isnot essential to qualify for 1981 protection," he wrote.
Finally, White established the criteria for filing a discrimination complaintunder Section 1981 of the U.S. Code. "If respondent on remand can prove thathe was subjected to intentional discrimination based on the fact that he wasborn an Arab, rather than solely on the place or nation of his origin, or his religion, he will have made out a case under 1981," White wrote.
Impact
The decision issued by the Supreme Court in Saint Francis College v. Al-Khazraji established clear guidelines for future discrimination claims under Section 1981 of the U.S. Code. It reaffirmed the Court's long-standing opinion that, as Justice Brennan observed in his concurring opinion, "perniciousdistinctions among individuals based solely on their ancestry are antithetical to the doctrine of equality upon which this nation is founded."
Related Cases
Saint Francis College et al.
Respondent
Majid Ghaidan Al-Khazraji, etc.
Petitioners' Claim
That a section of the U.S. Code barring racial discrimination did not apply to persons of Arab ancestry.
Chief Lawyer for Petitioners
Nick S. Fisfis
Chief Lawyer for Respondent
Caroline Mitchell
Justices for the Court
Harry A. Blackmun, William J. Brennan, Jr., Thurgood Marshall, Sandra Day O'Connor, Lewis F. Powell, Jr., William H. Rehnquist, Antonin Scalia, John PaulStevens, Byron R. White (writing for the Court)
Justices Dissenting
None
Place
Washington, D.C.
Date of Decision
18 May 1987
Decision
Affirmed the decision of the U.S. Court of Appeals and granted the respondentthe right to state his claim of racial discrimination against St. Francis College.
Significance
The Supreme Court's decision in Saint Francis College v. Al-Khazraji clarified the criteria for making a racial discrimination claim under section1981 of the U.S. Code.
The Facts of the Case
Professor Majid Ghaidan Al-Khazraji, a U.S. citizen born in Iraq, served on the faculty of St. Francis College in Pennsylvania. In January of 1978, he applied for academic tenure, but the college's board of trustees denied his request. Al-Khazraji later left the school's employ and filed complaints with thePennsylvania Human Relations Commission and the Equal Employment Opportunities Commission (EEOC). Upon advice from the EEOC, Al-Khazraji filed suit in U.S. District Court in 1980, claiming his tenure had been denied on the basis of race, in violation of the U.S. Code.
The Lower Courts Rule
The U.S. District Court first had to determine whether the statute of limitations had expired on Al-Khazraji's right to sue. It held that six-year limitation applied to this case and that Al-Khazraji, therefore, had a right to bring his action in court. The district court then proceeded to the question of Al-Khazraji's right to sue based on racial discrimination. The issue was whether an Arab, classified as a Caucasian under commonly accepted racial criteria, could charge racial discrimination under the U.S. Code. At first, the courtsided with Al-Khazraji and ruled that he could, but when St. Francis Collegemoved for summary judgement before a different judge, the court ruled in itsfavor. The second judge interpreted Al-Khazraji's complaint asserting only discrimination on the basis of national origin and religion, not race. Al-Khazraji then appealed this decision to the U.S. Court of Appeals for the Third Circuit.
The court of appeals reversed the district court's ruling on the merits of the case. It also applied the statute of limitations and ruled that Al-Khazrajihad filed his suit in a timely manner. It reasoned that while under currentracial classifications Arabs are Caucasians, Al-Khazraji could file a discrimination complaint because Congress had intended to protect all members of anygroup "that is ethnically and physiognomically distinctive." St. Francis College then appealed this decision to the U.S. Supreme Court.
The Supreme Court Affirms
On 18 May 1987, the Supreme Court ruled on the case. In a unanimous decision,the Court affirmed the ruling of the court of appeals and allowed Al-Khazraji to proceed with his complaint. As had two previous courts before it, the Supreme Court first established that there was no "time bar" to Al-Khazraji's complaint, since the six-year statute of limitations applied in this instance.It then moved on to the merits of the case.
In his majority opinion, Justice White made three key determinations. First,he concurred with the ruling of the court of appeals that held that Congresshad intended for its anti-discrimination legislation to encompass even thosecitizens who would be considered Caucasian under commonly accepted racial classification guidelines. After outlining the history and usage of the term "race" in Western culture, White concluded: "We have little trouble in concluding that Congress intended to protect from discrimination identifiable classesof persons who are subjected to intentional discrimination solely because oftheir ancestry or ethnic characteristics."
Next, White addressed the question of whether persons attempting to claim racial discrimination under Section 1981 must exhibit physical characteristics that single them out for identification--and by extension prejudice. To White,such visible differences were not necessary. "[A] distinctive physiognomy isnot essential to qualify for 1981 protection," he wrote.
Finally, White established the criteria for filing a discrimination complaintunder Section 1981 of the U.S. Code. "If respondent on remand can prove thathe was subjected to intentional discrimination based on the fact that he wasborn an Arab, rather than solely on the place or nation of his origin, or his religion, he will have made out a case under 1981," White wrote.
Impact
The decision issued by the Supreme Court in Saint Francis College v. Al-Khazraji established clear guidelines for future discrimination claims under Section 1981 of the U.S. Code. It reaffirmed the Court's long-standing opinion that, as Justice Brennan observed in his concurring opinion, "perniciousdistinctions among individuals based solely on their ancestry are antithetical to the doctrine of equality upon which this nation is founded."
Related Cases
- McNally v. United States, 483 U.S. 350 (1987).
- Patterson v. McLean Credit Union, 485 U.S. 617 (1988).
- Jett v. Dallas Independent School District, 491 U.S. 701 (1989).
- Lampf v. Gilbertson, 501 U.S. 350 (1991).
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