Although the Spun Steak decision recognizes that English-only rules may impact Title VII in some circumstances, the court held that an employer's good-faith imposition of these rules on fully bilingual employees does not violate Title VII. Section II of this Comment presents an overview of the substantive law and the enforcement mechanisms of Title VII. Section III outlines the development of federal discrimination law regarding English-only rules. Section IV examines the Spun Steak decision, and Section V analyzes the implications of this decision and its effect on discrimination law in the Ninth Circuit.
Dan Clawson, Garcia v. Spun Steak Co.: The Ninth Circuit Requires That Title VII Plaintiffs Prove the Adverse Effect of a Challenged English-Only Workplace Rule, 17 SEATTLE U. L. REV. 473 (1994).