Teamsters Local Union No. 117 v. WA Dep't of Corr., No. 13-35331 (9th Cir. 2015)
Annotate this CaseThe prison guards' union filed suit challenging Washington state's designation of female-only correctional positions as discrimination based on sex in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e. The court concluded that the state's individualized, well-researched decision to designate discrete sex-based correctional officer categories was justified because sex is a bona-fide occupational qualification (“BFOQ”) for those positions. The court found that the state was well-justified in concluding that rampant abuse should not be an accepted part of prison life and taking steps to protect the welfare of inmates under its care. Accordingly, the court affirmed the district court's grant of summary judgment in favor of the state.
Court Description: Labor Law. Affirming the district court’s summary judgment, the panel held that the Washington Department of Corrections did not discriminate against male correctional officers on the basis of sex in violation of Title VII by designating a number of female-only correctional positions in women’s prisons. The panel denied the Department’s motion to dismiss the appeal, holding that the record, as supplemented on appeal, established standing on the part of the correctional officers’ union. On the merits, the panel concluded that the Department’s individualized, well-researched decision to designate discrete sex-based correctional officer categories was justified because sex was a bona-fide occupational qualification reasonably necessary to the normal operation of the women’s prisons. The panel stated that the Department was well-justified in concluding that rampant abuse should not be an accepted part of prison life and taking steps to protect the welfare of female inmates under its care. TEAMSTERS LOCAL UNION NO. 117 V. WASH. DEP’T OF CORR. 3
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