Patterson v. McLean Credit Union

E165272

Patterson v. McLean Credit Union is a 1989 U.S. Supreme Court case that narrowly interpreted federal employment discrimination protections, prompting Congress to expand and clarify those rights in the Civil Rights Act of 1991.

All labels observed (1)

Label Occurrences
Patterson v. McLean Credit Union canonical 3

How this entity was disambiguated

Statements (44)

Predicate Object
instanceOf United States Supreme Court case
employment discrimination case
allegation discriminatory failure to promote
racial harassment in the workplace
areaOfLaw civil rights law
employment law
arguedDate 1988-12-07
citation 491 U.S. 164
concurrenceBy John Paul Stevens
Thurgood Marshall
William J. Brennan Jr.
country United States of America
surface form: United States
court Supreme Court of the United States
decidedIn October Term 1988
decisionDate 1989-06-15
decisionType 5–4 decision
dissentBy Harry A. Blackmun
docketNumber 87-107
effectOnLaw limited federal remedies for post-formation employment discrimination under § 1981 until 1991
fullCaseName Patterson v. McLean Credit Union self-link
holding 42 U.S.C. § 1981 covers discrimination in the making and enforcement of contracts, but not conduct by the employer after the contract relation has been established
failure to promote is actionable under § 1981 only if the promotion would create a new and distinct contractual relationship
racial harassment relating to conditions of employment is not actionable under § 1981 as then written
influenced enactment of the Civil Rights Act of 1991
joinedByInMajority Antonin Scalia
Byron R. White
Sandra Day O’Connor
William H. Rehnquist
jurisdiction federal question jurisdiction
languageOfOpinion English
legalIssue racial discrimination in employment
scope of 42 U.S.C. § 1981
majorityOpinionBy Anthony M. Kennedy
overruledInPartByStatute Civil Rights Act of 1991
petitioner Brenda Patterson
precedentFor narrow interpretation of § 1981 prior to 1991 amendments
raceOfPlaintiff Black Americans
surface form: African American
rearguedDate 1989-04-26
relatedCase Jones v. Alfred H. Mayer Co.
Runyon v. McCrary
respondent McLean Credit Union
statuteInterpreted 42 U.S.C. § 1981
subsequentDevelopment Civil Rights Act of 1991
surface form: Congress expanded § 1981 to cover post-formation discrimination in employment through the Civil Rights Act of 1991
subsequentHistory partially superseded by statute through Civil Rights Act of 1991 expansion of § 1981

How these facts were elicited

Referenced by (3)

Full triples — surface form annotated when it differs from this entity's canonical label.

Civil Rights Act of 1991 respondsToCourtDecision Patterson v. McLean Credit Union
Patterson v. McLean Credit Union fullCaseName Patterson v. McLean Credit Union self-link
Public Law 102-166 respondsTo Patterson v. McLean Credit Union