Patterson v. McLean Credit Union — Quick Summary

Patterson v. McLean Credit Union

491 U.S. 164 (1989)

In Brief

Patterson v. McLean Credit Union is a landmark case that interprets the reach of Section 1981 of the Civil Rights Act of 1866 in the context of employment discrimination.

Key Issue

Does Section 1981 of the Civil Rights Act of 1866 cover claims of racial harassment and other forms of improper treatment that occur after the formation of a contract, particularly in the context of employment?

The Rule

Section 1981 of the Civil Rights Act of 1866 provides that all persons within the United States have the right to make and enforce contracts as enjoyed by white citizens, which historically was understood to cover conduct related to the formation and enforcement of contracts.

Bottom Line

The Supreme Court held that Section 1981 does not extend to cover racial harassment or other discriminatory conduct occurring after the formation of a contract. The statute is limited to issues regarding the creation and enforcement of contracts.

Why It Matters

Patterson v. McLean Credit Union is significant for law students as it clarifies the limitations of Section 1981 concerning racial discrimination claims in employment. It serves as a key precedent in understanding the interplay between different civil rights statutes, particularly Section 1981 and Title VII. The decision underscores the importance of statutory language and legislative intent in interpreting civil rights protections. Law students must understand the boundaries delineated by the Court in this case, as it highlights the judicial process's role in mediating statutory interpretation with policy implications in civil rights law.

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