Personnel Administrator of Massachusetts v. Feeney

Personnel Administrator of Massachusetts v. Feeney, 442 U.S. 256 (1979), is a landmark decision of the United States Supreme Court.

Massachusetts law gave absolute hiring preference to veterans for state civil service positions. Because 98% of veterans were men, the law had a devastating effect on women’s state employment opportunities. Helen Feeney, a woman who had passed several civil service exams but was repeatedly passed over for veterans, challenged the law as gender discrimination under the Equal Protection Clause.

Significance

Justice Stewart’s 7-2 opinion upheld the preference, applying the Washington v. Davis intent requirement. The Court found that the law was not adopted with the purpose of discriminating against women — it was intended to reward veterans. While the law had a foreseeable disparate impact on women, proof of discriminatory purpose requires that the decisionmaker ‘selected or reaffirmed a particular course of action at least in part because of, not merely in spite of, its adverse effects upon an identifiable group.’

Category

US Federal Case Law