Wards Cove Packing Co. v. Atonio
E165271
Wards Cove Packing Co. v. Atonio is a 1989 U.S. Supreme Court case that narrowed the standards for proving employment discrimination under Title VII, prompting Congress to later revise those standards in the Civil Rights Act of 1991.
All labels observed (3)
| Label | Occurrences |
|---|---|
| Wards Cove Packing Co. v. Atonio canonical | 3 |
| Wards Cove Packing Co., Inc., et al. v. Atonio et al. | 1 |
| Wards Cove Packing Company, Inc. | 1 |
How this entity was disambiguated
This entity first appeared as the object of triple T1440273 — resolving that mention is where its identity was fixed. The disambiguator weighed these candidate entities and picked the highlighted one (or “None”, minting a new entity). This is how homonymy is resolved: the same surface form can point to different entities.
NED1
Entity disambiguation (via context triple)
gpt-5-mini-2025-08-07
Target entity: Wards Cove Packing Co. v. Atonio Context triple: [Civil Rights Act of 1991, respondsToCourtDecision, Wards Cove Packing Co. v. Atonio]
-
A.
United States v. Darby
United States v. Darby is a 1941 U.S. Supreme Court case that upheld federal labor regulations under the Commerce Clause and marked a broad expansion of federal power over economic activity.
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B.
Griggs v. Duke Power Co.
Griggs v. Duke Power Co. is a 1971 U.S. Supreme Court decision that established the doctrine of disparate impact in employment discrimination law, holding that seemingly neutral job requirements that disproportionately exclude protected groups can violate Title VII.
-
C.
Katzenbach v. Morgan
Katzenbach v. Morgan is a 1966 U.S. Supreme Court case that upheld Congress’s power under the Fourteenth Amendment to prohibit certain state voting restrictions, reinforcing federal authority to protect voting rights.
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D.
Employment Division v. Smith
Employment Division v. Smith is a landmark 1990 U.S. Supreme Court decision that significantly narrowed protections for religious practices under the Free Exercise Clause by upholding the enforcement of neutral, generally applicable laws even when they incidentally burden religion.
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E.
McDonnell Douglas Corp. v. Green
McDonnell Douglas Corp. v. Green is a 1973 U.S. Supreme Court decision that established the key burden-shifting framework for proving employment discrimination under Title VII.
- F. None of above. chosen
- G. Unsure - the case is ambiguous/there is not enough information to decide.
NED2
Entity disambiguation (via description)
gpt-5-mini-2025-08-07
Target entity: Wards Cove Packing Co. v. Atonio Target entity description: Wards Cove Packing Co. v. Atonio is a 1989 U.S. Supreme Court case that narrowed the standards for proving employment discrimination under Title VII, prompting Congress to later revise those standards in the Civil Rights Act of 1991.
-
A.
United States v. Darby
United States v. Darby is a 1941 U.S. Supreme Court case that upheld federal labor regulations under the Commerce Clause and marked a broad expansion of federal power over economic activity.
-
B.
Griggs v. Duke Power Co.
Griggs v. Duke Power Co. is a 1971 U.S. Supreme Court decision that established the doctrine of disparate impact in employment discrimination law, holding that seemingly neutral job requirements that disproportionately exclude protected groups can violate Title VII.
-
C.
Katzenbach v. Morgan
Katzenbach v. Morgan is a 1966 U.S. Supreme Court case that upheld Congress’s power under the Fourteenth Amendment to prohibit certain state voting restrictions, reinforcing federal authority to protect voting rights.
-
D.
Employment Division v. Smith
Employment Division v. Smith is a landmark 1990 U.S. Supreme Court decision that significantly narrowed protections for religious practices under the Free Exercise Clause by upholding the enforcement of neutral, generally applicable laws even when they incidentally burden religion.
-
E.
McDonnell Douglas Corp. v. Green
McDonnell Douglas Corp. v. Green is a 1973 U.S. Supreme Court decision that established the key burden-shifting framework for proving employment discrimination under Title VII.
- F. None of above. chosen
Statements (46)
| Predicate | Object |
|---|---|
| instanceOf |
Title VII case
ⓘ
United States Supreme Court case ⓘ employment discrimination case ⓘ |
| citation | 490 U.S. 642 ⓘ |
| congressionalResponse | Several aspects of the decision were superseded by statute in the Civil Rights Act of 1991. ⓘ |
| court | Supreme Court of the United States ⓘ |
| decisionDate | 1989-06-05 ⓘ |
| dissentBy |
Harry A. Blackmun
ⓘ
John Paul Stevens ⓘ
surface form:
John Paul Stevens (in part)
Thurgood Marshall ⓘ William J. Brennan Jr. ⓘ
surface form:
William J. Brennan, Jr.
|
| docketNumber | 87-1387 ⓘ |
| effectOnLaw | Narrowed the standards for proving disparate impact discrimination under Title VII prior to 1991. ⓘ |
| factualBackground | Nonwhite workers were concentrated in unskilled cannery jobs while white workers held skilled and noncannery positions. ⓘ |
| fullCaseName |
Wards Cove Packing Co. v. Atonio
self-linksurface differs
ⓘ
surface form:
Wards Cove Packing Co., Inc., et al. v. Atonio et al.
|
| holding |
In disparate impact cases under Title VII, the proper comparison is between the racial composition of the at-issue jobs and the racial composition of the qualified labor pool, not the employer’s total workforce.
ⓘ
Once a plaintiff establishes a disparate impact, the employer’s burden is one of production to show a business justification, not a burden of persuasion. ⓘ Plaintiffs in a disparate impact case must identify the specific employment practice that is challenged. ⓘ Plaintiffs retain the ultimate burden of persuasion on the issue of whether a challenged practice is justified by business necessity. ⓘ |
| impact | Shifted more of the burden in disparate impact cases onto plaintiffs until the 1991 amendments. ⓘ |
| industryContext | Alaska salmon canning industry ⓘ |
| influenced | Civil Rights Act of 1991 ⓘ |
| issue | Whether statistical disparities in workforce composition alone established a prima facie case of disparate impact under Title VII. ⓘ |
| joinedByInMajority |
Anthony M. Kennedy
ⓘ
Antonin Scalia ⓘ John Paul Stevens (in part and in the judgment) ⓘ Sandra Day O’Connor ⓘ
surface form:
Sandra Day O'Connor
William H. Rehnquist ⓘ |
| jurisdiction |
United States of America
ⓘ
surface form:
United States
|
| legalArea |
civil rights law
ⓘ
employment law ⓘ labor law ⓘ |
| legalConcept |
burden of proof
ⓘ
business necessity ⓘ disparate impact ⓘ |
| legalProvision | Title VII of the Civil Rights Act of 1964 ⓘ |
| majorityOpinionBy | Byron R. White ⓘ |
| overruledByStatute | Civil Rights Act of 1991 ⓘ |
| petitioner |
Wards Cove Packing Co. v. Atonio
self-linksurface differs
ⓘ
surface form:
Wards Cove Packing Company, Inc.
|
| precedentStatus | Partially superseded by statute but still cited for certain disparate impact principles. ⓘ |
| relatedCase |
Civil Rights Act of 1991
ⓘ
Griggs v. Duke Power Co. ⓘ Watson v. Fort Worth Bank & Trust ⓘ |
| respondent | Frank Atonio ⓘ |
| standardOfReview | disparate impact analysis under Title VII ⓘ |
| timePeriod | Rehnquist Court ⓘ |
How these facts were elicited
The pipeline generated the facts above by prompting gpt-5.1 with this entity's name + description and the instruction below.
Instruction
You are a knowledge base construction expert. Given a subject entity and a description of it, return factual statements that you know for the subject as a JSON list of dictionaries(triples), where keys must be "subject", "predicate" and "object". The number of facts may be very high, between 25 to 50 or more, for very popular subjects. For less popular subjects, the number of facts can be very low, like 5 or 10. # Requirements - If you don't know the subject at all, return an empty list. - If the subject is not a named entity, return an empty list. - Include at least one triple where predicate is "instanceOf". - Do not get too wordy. - Separate several objects into multiple triples with one object.
Input
Subject: Wards Cove Packing Co. v. Atonio Description of subject: Wards Cove Packing Co. v. Atonio is a 1989 U.S. Supreme Court case that narrowed the standards for proving employment discrimination under Title VII, prompting Congress to later revise those standards in the Civil Rights Act of 1991.
Referenced by (5)
Full triples — surface form annotated when it differs from this entity's canonical label.
Wards Cove Packing Co. v. Atonio
→
fullCaseName
→
Wards Cove Packing Co. v. Atonio
self-linksurface differs
ⓘ
this entity surface form:
Wards Cove Packing Co., Inc., et al. v. Atonio et al.
Wards Cove Packing Co. v. Atonio
→
petitioner
→
Wards Cove Packing Co. v. Atonio
self-linksurface differs
ⓘ
this entity surface form:
Wards Cove Packing Company, Inc.