Conceding that the CPs had established a prima facie case, R defended on concerned with public preference in such jobs, the males and females are similarly situated. entitled, Advance Data from Vital Health Statistics, No. Dothard v. Rawlinson, 433 U.S. 321, 14 EPD 7632 (1977); citing Griggs v. Duke Power Co., 401 U.S. 424, 3 EPD 8137 (1971). If Senior Constable Lim was much lighter, meanwhile, he would be ineligible to give blood. CP conjectures that the opposite, namely that men are taller than women, must also be true. The respondent's contention that the minimum requirements bore a relationship to strength was rejected outright since no supportive evidence was produced. and 28% of all men, that she was being discriminated against because of her sex. Applicants must be between 60 and 80 inches in height, and be between 18 and 39 years of age. This basic In its defense the respondent had its supervisory personnel testify that the minimum International v. United Air Lines, Inc., 408 F. Supp. exclude Black applicants, while liberally granting exceptions to White applicants. As a result, argues CP, standard height/weight limits disproportionately exclude Black females, as opposed to White females, from flight attendant positions. The EOS should therefore refer to the decisions and examples set out in the following section for guidance. (ii) Four-Fifths Rule - It may not be appropriate in many instances to use the 4/5ths or 80% rule, which is a general rule of thumb or guide for determining whether there is evidence of adverse positions constitutes unlawful sex discrimination in violation of Title VII. * As an example, determine if there is evidence of adverse impact. As long as some women can successfully perform the job, the respondent cannot successfully rely on the narrow BFOQ Reference can be made to general principles of adverse impact analysis and analogies can be drawn to court cases. Jog up three floors and then descend, four times 3. R alleges that its concern for the adjustable seats on some vehicles and to a lesser extent, adjustable steering wheels. No such restrictions were placed on the hiring of other personnel such as file clerks, secretaries, or professionals. Investigation revealed that R's reason for the weight requirement was public preference for shapely females in public contact positions. maximum weight in proportion to their height and body size based on standard height/weight charts. The example which follows illustrates discriminatory use of a minimum weight standard. She alleged that only females were disciplined for exceeding the maximum weight limit, while similarly situated males were not. The respondent did not show the existence of a valid relationship between strength and weight. EOS should consult the Uniform Guidelines on Employee Selection Procedures at 29 C.F.R. Other courts have concluded that imposing different maximum weight requirements for men and women of the same height to take into account the physiological differences between the two groups does not violate Title VII. of a disproportionate number of women and to a lesser extent other protected groups based on sex, national origin, or race. (Where other than public contact positions are involved, Height/Weight Standards: . Dillmann is 1.615 meters tall - 1.5 centimeters too short. As was suggested above, the respondent cannot rely on the narrow BFOQ exception based on sex or on general unfounded assertions about the relationship of strength to weight to R was unable to refute the availability of less restrictive alternatives; therefore, the minimum height requirement was discriminatory. females. standard, R replaced the height/weight requirement with a physical female. When such charges are presented, the charging party should be apprised that courts have There, females could not be over 5'9" tall, while males could not be over 6'0" tall. I have been informed that, at present, the firefighters council requires all applicants for employment as firefighters to be at least 5'6" in height, with weight proportionate to height. subject to the employees' personal control. Title VII, 29 CFR Part 1604, 29 CFR Part 1605, Employers, Employees, Applicants, Attorneys and Practitioners, EEOC Staff, Commissioner Charges and Directed Investigations, Office of Civil Rights, Diversity and Inclusion, Management Directives & Federal Sector Guidance, Federal Sector Alternative Dispute Resolution, Advance Data from Vital Health Statistics, No. HOUSTON POLICE DEPARTMENT HEIGHT AND WEIGHT CHART Exceptions are granted for an applicant whose height and weight is proportioned, or an applicant with a muscular or athletic build. Height and Weight Qualifications Most police departments impose proportional weight-to-height restrictions on incoming recruits. man of medium stature would therefore be permitted to weigh proportionally more than a 5'7" woman of medium stature on the same height/weight chart. that as a result, a maximum height requirement disproportionately excludes them from employment. 1980), and Vanguard Justice Society Inc. v. Hughes, 471 F. Supp. The following table of height and weight is to be adhered to in all instances except where a particularly unusual situation is found and is documented by a special report of the examining physician. (See 621.1(b)(2)(i), above.) ), Additionally, the EOS should remember that strength is not a characteristic peculiar to the male sex. officer. For further guidance in analyzing charges of disparate treatment, the EOS should refer to 604, Theories of Discrimination. Therefore, R is discriminating by nonuniform application of its minimum height policy. for the safe and efficient operation of its business. Investigation revealed nonuniform application of the tests. 5'7 1/3". female applicant who was not hired for a vacant flight attendant position, filed a charge alleging adverse impact based on race. Washington, DC 20507 Absent such a showing, a prima facie case is not established. requirements have been set for females as opposed to males. CP, a female who passed the wall, but not the sandbag requirement, filed a charge alleging sex discrimination 1107, 21 EPD 30,419 (E.D. defense for use of the requirement since a reasonable alternative, e.g., use of platforms to compensate for difference in height, existed. The Court Guide 6634; and Commission Decision No. substantial number of R's existing employees and new hires were under 5'8" tall. the council's promulgation of standards recognizes the multiple responsibilities to be fair to prospective candidates, and to duly consider the safety and welfare of the general public. Air Lines Inc., 430 F. Supp. is a minimum height/weight requirement, are applicants actually being rejected on the basis of physical strength. 1979). employees even though the labor market area from which it chose its employees was 14% Chinese. CPs argue that the standard charts fail for that reason to consider that Black females have a different body structure, physiology, and different proportional height/weight measurements than White females. proportional, minimum height/weight standards are considered a predictor or measure of physical strength, as opposed to the ability to lift a certain specific minimum weight. Andhra University 1st year question papers for B.Sc in Computers | Eligibility for admission in MSc paleontology? R defended on the ground that CP was not being treated differently from similarly situated males because there were no male stewards or passenger service representatives. Reasons for these minimum height standards are as varied as the employers, ranging from assumptions of public preferences for taller persons, to paternalistic notions regarding women, to assumptions that taller persons are physically In this respect the because the physical ability/agility test disproportionately excludes large numbers of women and is not justified by business necessity. The purpose of this study was to profile the current level of fitness for highway patrol officers based on age and . Hispanics from production jobs. Members of the 155th trooper training class salute during . were hired. Height and weight requirements for necessary job performance. Even though national statistics are used, 4(D) of the UGESP recognizes that there can still be evidence of adverse impact, often with very large numbers since a national pool is used, based on smaller percentage (1) Secure a detailed statement delineating exactly what kind of height and weight requirements are being used and how they are being used. When that happens, the Office of Legal Counsel, Guidance Division should be contacted for assistance. men must be disproportionately excluded from employment by a maximum height requirement, in the same manner as women are disproportionately excluded from employment by a minimum height requirement. Indeed, the In Commission Decision No. Recruitment of minorities is more important now more than ever because __________. Meanwhile, the maximum age requirement is often based on the amount of time it would take an officer to retire with full benefits . Then it was 5 feet, 6; since 1980, it has been 5 feet; who concocted those numbers, and on what criteria? evidence Black females were disproportionately excluded. Although there are no Commission decisions dealing with disparate treatment in the discriminatory use of a minimum weight requirement, an analogy can be drawn to Commission Decision No. noncontrollable trait peculiar to their group or class (see Example 2 above) should be accepted and analyzed in terms of adverse impact. Policy on height and weight requirements Printer-friendly version Next ISBN -7778-5903-3 Approved by the OHRC: June 19, 1996 (Please note: minor revisions were made in December 2009 to address legislative amendments resulting from the Human Rights Code Amendment Act, 2006, which came into effect on June 30, 2008.) A police department minimum height requirement of 67 inches was found in Dothard v. Rawlinson (cited below) to preclude consideration of more So I turned my interests into Emergency Medical Services. weigh proportionately more as a class than White females. This 1983 document addresses the application of EEO laws to employer rules setting a maximum height and/or weight for particular jobs. The question of what would constitute an adequate business necessity defense so as to entitle the employer to maintain minimum height standards was not addressed by the Court in Dothard v. Rawlinson, supra. It also believed that it was in the females' best interest that they not be so employed. weight requirement. In some cases, Many employers impose minimum weight requirements on applicants or employees. N.Y. 1979). 131 M Street, NE And, whether they are male or female is immaterial. Only when it can be determined as a matter of law that it is a question of weight as a mutable characteristic as in the Cox, supra type situation presented in Examples 1 and 3 above should further processing cease; otherwise as in Example (1) - Prison Correctional Counselors - In Dothard v. Rawlinson, supra, the Supreme Court found that applying a requirement of minimum height of 5'2" and weight of 120 lbs. R's police force was 98% White male, and 2% Black male. These two approaches are illustrated in the examples which follow. The minimum age for these requirements is 17. required to successfully perform a job. (since Asian women are presumably not as tall as American women) may not be applicable. Education: A college graduate by the time you're . 1980), dec. on rem'd from, ___ F.2d ___, 24 EPD 31,211 (5th Cir. On a case-by-case Share sensitive 1-844-234-5122 (ASL Video Phone), Call 1-800-669-4000 impact in the selection process, when analyzing height/weight requirements. Such charges might have the following form. Example (2) - R, a fire department, replaced its minimum height/weight standards with a physical ability/agility test. with discrimination based on sex, national origin, and to a lesser extent, race. Once in the service, reservists must meet height, weight and body fat standards. Applicant flow data showing that large numbers of Hispanic applicants were hired was not determinative since many others were probably rejected because of the standard. My junior year in high school I figured that I wasn't going to get any taller than the 5'6" I eventually became. the issue is non-CDP, and the Office of Legal Counsel, Guidance Division should be contacted.). Donors must have a body weight of at least 45-50kg. impact, instead of actual applicant flow data. Investigation revealed evidence supporting CP's contention and that R had no Chinese Harless v. Duck, 619 F.2d 611, 22 EPD 30,871 (6th Cir. 1607. sandbag up a flight of stairs and scale a 14-foot log wall. even if all functions of a police officer did require such force, a physical aptitude test is a more appropriate means of assessing candidate suitability, rather than relying on height (or age); and; up to 2003, Greek law imposed different height requirements for men and women seeking entry to the Police. women passed the wall requirement, and none passed the sandbag requirement. In Schick v. Bronstein, 447 F. Supp. CP alleged that the denial was based on her race, not on her height, because R hired other applicants under 5'8" tall. of the requirement was discriminatory since the respondent did not establish its use as a business necessity. (See generally Jefferies v. Harris County Community Action Association, 615 F.2d 1025, 22 EPD 30,858 (5th Cir. other police departments have similar requirements. Among the first screening tests were height and weight requirements. Investigation revealed that although the person hired was a White female, she 58. Except for a fact situation like the one suggested in 621.3(a) above, it is unlikely that a charging party will be able to establish that his protected group or class is on average taller than other groups or classes and Equal Employment Opportunity Commission. alternatives that have less of an adverse impact. strength necessary to successfully perform the job. Va. 1977), aff'd per curiam, 577 F.2d 869, 17 EPD 8373 (4th Cir. Succinctly stated by the court in Cox v. Delta Air geographical region that is not as tall as other Native Americans, it would not be appropriate to use national statistics on Native Americans in the analysis. of right to sue issued to protect the charging party's appeal rights. Accordingly, The defendants responded that height and weight requirements "have a relationship to strength, . Additionally, the Black female was unable to show that statistically (iii) Bottom Line - Under the bottom line concept which can be found in 4(C) of the UGESP, where height and weight requirements are a component of the selection procedure, even if considering all the components together there is no (See 619, Grooming Standards, for a detailed discussion of long hair cases.). (See 625, BFOQ, for a detailed treatment of the BFOQ exception.). That court left open the question of whether discrimination can occur where women are forced to resort to "diuretics, diet pills, and crash dieting" to meet disparate weight requirements. Please type your question or comment here and then click Submit. National statistics showed that the combined height and weight requirements excluded 41.13% of the female population, as Like the above example and in Commission Decision Nos. CP, an unsuccessful female job applicant weighing under 150 lbs., alleged, based on national statistics which showed that the minimum requirement would automatically exclude 87% of all women In the 1977 Dothard v. Rawlinson case, the plaintiffs showed that the height and weight requirements excluded more than 40 percent of women and less than 10 percent of men. for a police cadet position. The Aviation Class 1 limits include: a minimum height of 163cm and maximum of 193cm, a sitting height maximum of 100cm and a buttock-to-knee limit of 67cm. Here are the requirements to become a commissioned Officer: Age: At least 17, but under 31 in the year of commissioning as an Officer. In terms of disparate treatment, the airlines' practice of more frequently and more severely disciplining females, as compared to males, for violating maximum weight restrictions was found to violate Title VII. 76-45, CCH Employment Practices ), In other instances, instead of relying upon minimum proportional height/weight standards as a measure of strength, the respondents have abolished height and weight standards and have installed in their place physical ability tests. According to CP, Black females, because of a trait peculiar to their race and not subject to their personal control, 76-45 and 76-47 (cited above), statistical comparison data was not sufficiently developed or otherwise available from any source to enable the charging parties to show disproportionate The number of Hispanic females in the employer's workforce was double their representation in the relevant labor market, and there was no A slightly smaller range is not acceptable. As such, it is an immutable characteristic neither changeable nor Fla. 1976), aff'd, 14 EPD very charts which are standard, and which are relied on to establish height/weight in proportion to body size contain different permissible limits for men and women in recognition of the physiological differences between the two groups. The contents of this document do not have the force and effect of law and are not meant to bind the public in any way. The court found as a matter of law that In the context of minimum weight requirements, disparate treatment occurs when a protected group or class member is treated differently from other similarly situated employees for reasons prohibited under the Act. discrimination filed by a Black female is evaluated in terms of her race and sex separately); Payne v. Travenol Laboratories, Inc. , 673 F.2d 798, 28 EPD 32,647 (5th Cir. discrimination by showing that the particular physical ability tests disproportionately excluded a protected group or class from employment, the burden shifts to the respondent to show that the requirements are a business necessity and bear a 378, 11 EPD 10,618 (N.D. Cal. A minimum performance score is required on each of the subtests and are scored in a pass/fail manner. Rawlinson, supra, the Supreme Court found that applying a requirement of minimum height of 5'2 and weight of 120 lbs. In Example 2 above, the allegation is that weight, in the sense of Black females weighing more than White females, is a trait peculiar to a particular race. Additionally, where the numbers are very small, even though national statistics are used, the test of in discharge. The Navy may temporarily disqualify individuals under the weight standard, which allows applicants time to gain the weight they need without preventing them from enlisting entirely. Standards ranged from 152 cm in Belgium to 170 cm in Greece, Malta, and Romania. For decades, the LAPD demanded that its officers measure up to 5 feet, 8 inches. An official website of the United States government. Out of the next class of 150 applicants, 120 men and 30 women, only two Accord Horace v. City of Pontiac, 624 F.2d 765, 23 EPD 31,069 (6th Cir. (See 621.1(b)(2)(i) above and A healthy and fit lifestyle is an essential element of being a police officer. Solicit specific examples to buttress the general allegations. (4) Determine if other employees or applicants are affected by the use of height and weight requirements. revealed that although only two out of 237 female flight attendants employed by R are Black, there is no statistical or other evidence indicating that Black females as a class weigh more than White females. Close A related body of scholarship also suggests that, on average, female police officers are more adept at avoiding violent confrontations in the first instance. Over a two-year period 1 male and 15 females were discharged for failing to maintain the proper weight. It is changeable, it is controllable within age and medical limits, and it is not a trait peculiar to presented to the Commission by Black and Hispanic women both groups were unable to meet the first requirement of proving statistically that, on average, their groups weighed more. In Commission Decision No. In contrast, 5 of the men failed both requirements. The minimum height for a female (of general category) & ST (not of SC or OBC) according to the physical criteria for IPS should be 150 cm. v. Duke Power Co., 401 U.S. 424, 3 EPD 8137 (1971). For example, even though there 1979). course be less. 79-19, CCH Employment Practices Guide 6749, a male, 5'6" tall, challenged the application of the minimum, 5'5" female and 5'9" male, height requirement and alleged that if he were a female he could have qualified In order to establish that a group member protected under Title VII was adversely affected by a maximum height requirement, it must first be shown that the particular group of which (s)he is a member would be disproportionately affected by such a 3 (November 19, 1976), and No. Lift and drag a 165-pound mannequin 40 feet 4. and over possessed the physical Employees or applicants of federal agencies should contact their EEO Counselor. The Court found that imposition (BMI calculator says you are underweight). (Whether or not adverse impact can be found in this situation is 71-1418, CCH EEOC Decisions (1973) 6223. 1972). (2) Determine the Title VII basis, e.g., race, color, sex, national origin or religion, of the complaint, and the issues or allegations as they relate to a protected justification for its actions, the employee has the opportunity to show that the employer's reason is merely a pretext for discrimination. In addition to physiological differences, arguments have been advanced that weight is not an immutable characteristic (see 621.5(a)) and that policies based on personal appearance (see 619, Grooming Standards) do not result in Investigation revealed that the weight policy was strictly applied to females, that females were 1982) (where a distinction is made as to treatment 1980); Blake v. City of Los Angeles, 595 F.2d 1367, 19 EPD 9251 (9th Cir. 14 (November 30, 1977). of the employment policy or practice. police officer. Many height statutes for employees such as police officers, state troopers, firefighters, correctional counselors, flight attendants, and pilots contain height ranges, e.g., 5'6" to 6'5". Example (1) - R, police force, has a maximum height requirement of 6'5". The Court in Dothard (cited below and discussed in 621.1(b)(2)(iv)) stated that since otherwise qualified individuals might be discouraged from applying because of their Example (1) - R had an announced policy of hiring only individuals 5'8" or over for its assembly line positions. 3. b. the media's portrayal of law enforcement officers. (See Commission Decision No. 71-1529, CCH EEOC Decisions (1973) 6231; Commission The employees, with few exceptions, performed light assembly work on the finished product. According to respondent, taller officers enjoyed a psychological advantage and thus would less often be attacked, were better able to subdue suspects, and possible that reliance on the charts could result in disproportionate exclusion of Black females, the EOS should continue to investigate this type of charge for adverse impact. are not job related. In Commission Decision No. N.Y. 1978), a police department's application of different minimum height requirements for males as opposed to females was found to constitute sex discrimination. Example (3) - State Troopers - As with police departments, applying minimum size requirements to applicants for state trooper jobs violates Title VII, unless the respondent can establish that the requirements are necessary 76-47, CCH Employment Practices Guide 6635, where adverse impact was alleged, the Commission concluded that absent evidence that Blacks as a class, based on a standard height/weight chart, proportionally weigh group or class and not against others. In Commission Decision No. In order to establish a prima facie case of adverse impact regarding use of maximum weight requirements, a protected group or class member would have to show disproportionate exclusion of his/her protected group or class because of Also, there was no evidence of disparate treatment. 1607; and 610, Adverse Impact in the Selection Process, which is forthcoming.). 1975). . Investigation revealed that R did in fact accept and train Whites Find your nearest EEOC office Anglos testified that they were not aware of the existence of the physical ability/agility tests. The same is true if there are different requirements for different group or class members, e.g., where the employer has a 5'5" minimum height requirement Using a different standard for females as opposed to males was found to violate the Act. The compared to less than 1% of the male population. according to its statutory mandate the municipal police training council established physical standards for male and female officers. (This problem is discussed further in 621.6, below.). The court in U.S. v. Lee Way Motor Freight, Inc., 7 EPD 9066 (D.C. Ok. 1973), found that a trucking company's practice of nonuniform application of a minimum height requirement constituted prohibited race discrimination. study showing that taller police officers are assaulted less, have less probability of being injured, receive fewer complaints, and have fewer auto accidents. For instance, if the charging party is from a particular Indian tribe located almost exclusively in a particular For many types of jobs minimum height standards have been established by employers. based on standard height/weight charts. (i) If there are documents get copies. (See also EEOC v. Delta Air Lines, Inc., ___ F. Supp. objects. Official websites use .gov The respondent must consider individual abilities and capabilities. Weight at BMI 17.5. The direct and obvious effect of minimum height or weight requirements is, as stated in 621.1(a) above, to disproportionately exclude significant numbers of women, Hispanics, and certain Asians from CP, a female stewardess who was disciplined for being overweight, filed a charge alleging that she was being discriminated against This guidance document was issued upon approval by vote of the U.S. proportion to height based on national height/weight charts. (The EOS should also refer to the discussion of Dothard v. Rawlinson in 621.1(b)(2)(iv), where it was found that, as a trait peculiar to females, they weigh less than males. What you'll need to achieve in each event to earn . The respondent's contention that it could not otherwise readily transfer people to different positions unless the minimum height requirement was maintained, since some positions require employees of a certain requirements. (See Appendix I.). Fact situations may eventually be presented that must be addressed. For instance, in U.S. v. Lee Way Motor Freight Inc., 7 EPD 9066 (D.C. Okla. 1973), the respondent, a trucking company, strictly applied its height and weight requirements for driver to applicants for guardpositions constitutes unlawful sex discrimination in violation of Title VII. The Physical Ability Test consists of three subtests; sit-ups, push-ups and the 1.5 mile run. According to CPs, the standard height/weight charts are based on and reflect height and weight measurements of White females since they constitute the majority of the population, not Black females who b. the media's portrayal of law enforcement officers. self-recognized inability to meet the requirement, the application process might not adequately reflect the potential applicant pool. discrimination because weight in the sense of being over or under weight is neither an immutable characteristic nor a constitutionally protected category. 76-31, CCH Employment Practices Guide 6624, the Commission found no evidence of adverse impact against females with respect to a bare unsupported allegation of job denial based on sex, because of a minimum height ), In Example 1 above, weight, in the sense of females as a class being more frequently overweight than males, is a mutable characteristic. Most airlines require that its flight attendants not exceed a As the following examples suggest, charges in this area may also be based on disparate treatment, e.g., that female flight attendants are being treated differently by nonuniform application of a maximum weight requirement or that different (The issue of whether adverse impact 1607, there is a substantial difference and The EOS should also be aware that in many instances reliable statistical analyses may not be available. They also MUST be US citizens. ; and. Example (1) - Weight as Mutable Characteristic - R, an airline, has a policy under which male and female flight attendants are required to maintain their weight in proportion to their height based on national height/weight 1976), "under no set of facts can plaintiff recover on the legal theory she urgesbecause weight is neither an immutable characteristic nor a There were no female or Hispanic officers, even requirement, where there was no neutral height policy, and no one had ever been rejected based on height. Example (3) - Partial Processing Indicated - CPs, female restaurant employees, file a charge alleging that they are being discriminated against by R since it requires that all of its employees maintain the proper weight in City of East Cleveland, 363 F. Supp. 1980) (where a charge of Decided cases and decisions have dealt with both disparate treatment and adverse impact analyses, and manifest relationship to the employment in question. 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