Patterson v. McLean Credit Union

The effect of the Court's decision was profound. Although another civil rights law known as Title VII of the Civil Rights Act of 1964 does prohibit racial harassment by employers, that law applies only to companies with 15 or more employees, leaving over 11 million employees unprotected from racial harassment at the time of the Patterson decision. Following the decision, hundreds of claims of racial harassment were dismissed by courts. In 1991, Congress dealt with the problem by passing the Civil Rights Act of 1991. One section of this act explicitly overturned the Patterson decision by adding a new provision to section 1981. This new provision clearly provides that section 1981 prohibits all aspects of discrimination in contractual relationships, including harassment. Although Brenda Patterson lost her case, the civil rights advocates fighting for her cause were able to assure, through passage of the Civil Rights Act of 1991, that the harassment she suffered is now prohibited by section 1981.