Victorson v. Department of Treasury

Brickley, J.

(dissenting). I agree with the majority that the Legislature intended to encourage persons subject to the Civil Rights Act,1 through § 210,2 to voluntarily adopt affirmative action plans. I also agree with the majority’s holding that § 210 clearly requires that an affirmative action plan be filed with and approved by the Civil Rights Commission (crc) in order to be implemented. However, I disagree with the majority’s holding that an unapproved affirmative action plan may serve as a defense to a discrimination claim under *147the Civil Rights Act if the plan would be valid under federal civil rights law.3

I believe the majority misstates the issue in this case in terms of whether the failure to obtain approval of an affirmative action plan means that action taken pursuant to the unapproved plan is discriminatory as a matter of law. Ante, pp 133-134. The majority holds that such conduct is not itself discriminatory and that an. unapproved affirmative action plan may constitute a legitimate, nondiscriminatory reason for employment action. I do not find it necessary to decide, as does the majority, whether the Court of Appeals was correct in finding that the use of an unapproved plan is discriminatory per se. Certainly, merely having a plan does not violate the act, but it is difficult to envision an action taken pursuant to such a plan that would not violate the proscription of the Civil Rights Act against the consideration of religion, race, color, national origin, or sex. That the Legislature considered there to be a conflict between those acts prohibited by the statute and actions taken pursuant to an affirmative action plan is buttressed by the fact that it found it necessary to specify the conditions under which "[a] person subject to this article may adopt and carry out a plan to eliminate present effects of past discriminatory practices or assure equal opportunity . . . .” MCL 37.2210; MSA 3.548(210).

Thus, while affirmative action may be legitimate, it is seldom ever "nondiscriminatory.” Therefore, the issue that must be addressed is *148whether an unapproved affirmative action plan may constitute a legitimate reason for employment action alleged to be discriminatory. I would hold that an unapproved affirmative action plan is not a legitimate defense to a claim under the Civil Rights Act. I further conclude that, absent an approved plan, employment action taken "to eliminate present effects of past discriminatory practices or assure equal opportunity with respect to religion, race, color, national origin, or sex,” MCL 37.2210; MSA 3.548(210), that is alleged to be discriminatory, must be judged under the provisions of the Civil Rights Act that prohibit unlawful discrimination by employers, as if no affirmative action plan were implemented.

i

A determination of legislative intent must begin with the statutory language, and if such language is clear and unambiguous, no further judicial interpretation is warranted. In re Forfeiture of $5,264, 432 Mich 242, 248; 439 NW2d 246 (1989); Hiltz v Phil’s Quality Market, 417 Mich 335, 343; 337 NW2d 237 (1983); Grand Rapids v Crocker, 219 Mich 178, 182; 189 NW 221 (1922). Further, when the meaning is plainly expressed by the words of a statute, the wisdom of the provision is a matter of legislative responsibility and this Court may not interfere. City of Lansing v Lansing Twp, 356 Mich 641, 648; 97 NW2d 804 (1959). Finally, reliance on federal case law in construing a state statute is both inappropriate and misleading when the state statute clearly sets a higher standard for compliance than the analogous federal statute.

Like the majority, I conclude that the express language of § 210 leaves no doubt regarding the Legislature’s intent to allow persons subject to the *149act to adopt and implement affirmative action plans only upon approval by the crc. The express language of the statute states that such a plan may be adopted and carried out "if the plan is filed with the commission under rules of the commission and the commission approves the plan.” MCL 37.2210; MSA 3.548(210) (emphasis added). There can be no dispute that "if ” was used by the Legislature as a word of condition or contingency. See People v Merhige, 212 Mich 601, 610; 180 NW 418 (1920).

While the majority agrees that approval by the crc is mandatory, it omits any discussion of why an approval requirement is consistent with the purposes of the act. Such a requirement serves to prevent unlawful discrimination and also to encourage persons subject to the act to adopt and carry out affirmative action plans to eliminate the present effects of past discrimination and to assure equal opportunity. The act explicitly prohibits employment actions that are based on immutable characteristics, such as sex. MCL 37.2202; MSA 3.548(202). However, affirmative action plans adopted and carried out pursuant to § 210, by their very nature, involve employment actions that take into account such immutable characteristics.4 Be*150cause the primary goál of the Civil Rights Act is to eliminate all discrimination, it is not surprising that the Legislature has seen fit to centralize in the crc the approval of affirmative action plans, which by definition require discrete categorization based on sex, race, etc.5 Thus, centralized approval of affirmative action plans is certainly consistent with the overall purpose of the Civil Rights Act.

Neither does this construction of § 210 interpret it in such a manner as to bar or prohibit affirmative action by a public employer. See Johnson v Santa Clara Co Transportation Agency, 480 US 616, 629; 107 S Ct 1442; 94 L Ed 2d 615 (1987); Baker v Detroit, 483 F Supp 930 (ED Mich, 1979). Any person subject to the act may implement an affirmative action plan, once that plan has been filed with and approved by the crc. Even absent an approval requirement like that found in § 210, employers are subject to certain constraints in implementing affirmative action plans. See ante, pp 144-145.

These requirements for validity of a plan do not act to prohibit affirmative action measures, but, rather, merely prescribe the manner in which such measures may be implemented. Likewise, while mandatory approval pursuant to § 210 adds another necessary step to the process of adopting and carrying out a plan, it cannot be said to bar or prohibit affirmative action any more than the other undisputed requirements for implementation of a valid affirmative action plan. In fact, an affirmative action plan could assumedly have been *151validated by the crc in this case, had it been requested to do so, in far less time and with far less effort than it has taken to secure this Court’s pronouncement on the subject.

ii

Under the Civil Rights Act, authority to take a person’s sex into account in an employment decision flows only from § 210, which clearly allows the adoption and carrying out of an affirmative action plan only upon approval. The clear wording of § 210 evidences the Legislature’s intent to distinguish between affirmative action plans that are approved and those that are not. An affirmative action plan may be adopted and carried out "if the plan is filed with the commission under rules of the commission and the commission approves the plan.” Therefore, a plan may not be implemented, if it is not filed with and not approved by the crc. Because there can be no question that approval is mandatory, it follows, then, that failure to comply with the statutory requirement renders the affirmative action plan void. See People v Koval, 371 Mich 453, 459; 124 NW2d 274 (1963). See also Jones v Municipal Officers Electoral Bd, 112 Ill App 3d 926, 929-930; 68 Ill Dec 522; 446 NE2d 256 (1983). Therefore, an unapproved plan, though it may be valid under federal civil rights law, is invalid under the Civil Rights Act not because it is a flawed plan, but because the employer is without authority to promulgate such an unapproved plan.

The importance of, and the sole reason for, implementing affirmative action measures pursuant to a plan is that the plan, if valid, will serve as a rationale for employment action taken pursuant to it that would otherwise violate the provisions of the Civil Rights Act. As a rationale for the other*152wise discriminatory employment action, the plan is a defense to a discrimination claim. See Johnson, supra at 626. Because § 210 clearly only provides authority to implement an approved affirmative action plan, the Legislature could not have intended that an unapproved plan could also be a valid defense to such a claim. However, the majority’s holding allows an employer to use an unapproved plan as a defense to a discrimination claim under the Civil Rights Act, despite the fact that, under § 210 of the same act, the employer was not permitted to implement the plan in the first place. Such a construction makes the approval requirement in § 210 meaningless.

III

Despite the clear and unambiguous wording of § 210, leading to the conclusion that an unapproved affirmative action plan is invalid, and therefore not a legitimate defense to a discrimination claim under the Civil Rights Act, the majority concludes that an unapproved plan may be a legitimate defense as long as the plan would be valid under federal civil rights law.

A

While conceding that the Civil Rights Act requires an employer to obtain the approval of the crc before implementing an affirmative action plan, the majority states that the act does not make reference to unapproved plans, or to the consequences of utilization of an unapproved plan. Therefore, the majority argues, because the act is "silent” on this question, the answer lies in the interpretation of federal civil rights law by other courts.

*153The majority correctly points out that the Civil Rights Act does not mention unapproved affirmative action plans, and also does not expressly dictate that an employer may not use an unapproved plan as a defense to a discrimination claim. However, as the majority also concedes, throughout the act the Legislature has made explicit reference to approved plans. Moreover, the Legislature altered the language of §210 to require the crc to take an active role in the approval of affirmative action plans, thereby rejecting the original wording of § 210 that would have allowed the implementation of a plan as long as the crc did not disapprove of it. 1975 HB 4055, § 20. A similar change was made to § 705, which originally did not mention approval, 1975 HB 4055, § 68(2), so that § 705 now directs that the act "shall not be interpreted as restricting the implementation of approved plans ... to eliminate discrimination and the effects thereof when appropriate.” MCL 37.2705(2); MSA 3.548(705)(2) (emphasis added). In fact, nowhere does the act make reference to a plan intended to "eliminate present effects of past discriminatory practices or assure equal opportunity,” MCL 37.2210; MSA 3.548(210), without specifying that such a plan must be approved.

While the act does not clearly state the consequences of the implementation of an unapproved plan, the act also does not clearly state that an approved plan may be used as a defense to a discrimination claim. Such an explicit statement would be unnecessary because, as explained above, the only reason for implementing affirmative action pursuant to a plan is to provide an employer with a defense to a discrimination claim. However, what is unquestionably clear is that § 210 states that an employer may not implement a plan with*154out obtaining approval by the crc. Therefore, to say that the Civil Rights Act is "silent” on the subject of the consequences of failure to obtain approval of a plan is to ignore the explicit wording of § 210 and the logical interpretation that flows from it.

B

The majority also states that prohibiting an employer from using an unapproved affirmative tion plan as a defense to a discrimination claim under the Civil Rights Act "negates the purpose of civil rights legislation and the liberal construction afforded such remedial legislation.” Ante, pp 141-142.6 The majority would not, however, argue that the enforcement of any other unquestioned requirement for the validity of an affirmative action plan would "negate” the purpose of the Civil Rights Act. For example, as the majority notes, id., p 144, a plan that is not "temporary in nature” is not a valid plan and therefore cannot be a defense to a discrimination claim. The inability of an employer to use such an invalid plan as a defense to a discrimination claim certainly does not "negate” the purposes of the Civil Rights Act. Likewise, the fact that an employer may only rely on a valid plan, i.e., a plan that was approved by the crc, is not inconsistent with the purposes of the Civil Rights Act either._

*155C

Finally, rather than interpreting § 210 as written, the majority looks to federal case law construing title VII to determine what constitutes a valid affirmative action plan under our Civil Rights Act. By doing so, the majority eliminates almost entirely the effect of the approval requirement in § 210.7 I have no quarrel with the majority’s adoption of the order of proof established by the United States Supreme Court in McDonnell Douglas Corp v Green, 411 US 792; 93 S Ct 1817; 36 L Ed 2d 668 (1973). However, the order of proof in a title VII case cannot be used to determine what factors affect the validity of a plan under an entirely different act, the Michigan Civil Rights Act. Pursuant to § 210, an employer cannot implement, and therefore cannot use as a defense to a discrimination claim, an affirmative action plan that was not approved by the crc. Under McDonnell Douglas, therefore, such an unapproved plan is not a legitimate defense to a discrimination claim under the Civil Rights Act.

Reliance on federal case law interpreting title VII is also inappropriate and misleading because of the obvious differences between title VII and the Civil Rights Act: unlike our act, title VII does not explicitly permit voluntary affirmative action. Rather, 42 USC 2000e-2(j) provides only that

Nothing contained in this subchapter shall be interpreted to require any employer, employment agency, labor organization, or joint labor-management committee subject to this subchapter to *156grant preferential treatment to any individual or to any group because of the race, color, religion, sex, or national origin of such individual or group .... [Emphasis added.]

Because of this statutory language, the issue before the United States Supreme Court in United Steelworkers of America v Weber, 443 US 193; 99 S Ct 2721; 61 L Ed 2d 480 (1979), was whether to permit voluntary affirmative action at all. In Weber, the Court held that such voluntary affirmative action was permissible because to hold otherwise would be contrary to the spirit of title VII Id. at 201-202.8 The dissenters in Weber argued that the clear and unambiguous language of title VII precluded any voluntary affirmative action. Id. at 216, 220. .

Unlike title VII, our Civil Rights Act explicitly permits voluntary affirmative action pursuant to § 210, but only if an employer obtains the approval of the crc. MCL 37.2210; MSA 3.548(210). The majority certainly does not need to examine the spirit of the Civil Rights Act to determine whether it permits affirmative action. Therefore, the issue before the Court in Weber was quite different from the issue presented here. Though I also do not quarrel with the majority’s adoption of the factors, established by the United States Supreme Court in Weber, for determining the validity of a plan, the adoption of those factors by this Court cannot be at the expense of negating the clear requirement of § 210 that the use of an affirmative action plan is contingent on affirmative approval by the crc. While a plan may be valid under the Weber test, and therefore a legitimate defense to a title VII claim, the Weber factors alone clearly do not *157determine the validity of a plan under our Civil Rights Act. Absent approval pursuant to § 210, an employer has no authority to make an employment decision that would otherwise violate the antidiscrimination provisions of the Civil Rights Act. Thus, an unapproved plan is not a valid plan and clearly cannot be a legitimate defense to a discrimination claim under the Civil Rights Act. I would affirm the decision of the Court of Appeals.

J. Riley and Griffin, JJ., concurred with Brickley,

MCL 37.2101 et seq.; MSA 3.548(101) et seq.

MCL 37.2210; MSA 3.548(210).

I disagree with the majority’s recitation of the facts, implying that its result is correct because the most qualified applicant received the promotion in this case. The facts in the record do not support the conclusion that Ms. Siegla was more qualified than Mr. Victorson. What the record does reflect, however, is that Ms. Siegla was promoted because she is a woman. The only issue to be resolved is whether the Department of Treasury had the authority to promote her on this basis.

See J F Cavanaugh & Co v Detroit, 126 Mich App 627; 337 NW2d 605 (1983). In Cavanaugh, the Court of Appeals noted that the city’s requirement that all city contractors implement affirmative action plans "implicitly conflicts with state law which requires employers not to discriminate on the basis of religion, race, color, national origin, or sex.” Id. at 637. Following a quotation of the wording of § 210, the Court continued:

In view of the statute’s prohibition of discrimination, § 210 implicitly precludes the use of an affirmative action plan unless the plan is "filed with the [civil rights] commission under rules of the commission and the commission approves the plan.”

I agree with this conclusion, except that § 210 explicitly, rather than implicitly, precludes the use of an unapproved affirmative action plan.

The United States Supreme Court has stated that affirmative action measures, and the elimination of all governmentally imposed discrimination, which is the "core purpose” of the Fourteenth Amendment, are "related constitutional duties [that] are not always harmonious; reconciling them requires public employers to act with extraordinary care.” Wygant v Jackson Bd of Ed, 476 US 267, 277; 106 S Ct 1842; 90 L Ed 2d 260 (1986) (emphasis added).

The majority also asserts that my construction of the Civil Rights Act is contrary to its legislative history. However, in support of this assertion, the majority does not cite any legislative history, but instead cites several executive directives indicating support for affirmative action. I do not disagree with the majority that through § 210 the Legislature intended to encourage voluntary implementation of affirmative action plans. However, nothing in the executive directives can negate the fact that § 210 encourages voluntary affirmative action only upon approval by the crc.

According to the majority’s analysis, the only significance remaining for failure to obtain approval of a plan by the crc is that the defendant, rather than the plaintiff, has the burden of showing that the plan is valid under the requirements specified by the United States Supreme Court, with regard to title VII.

This conclusion was reiterated by the majority with regard to public employers in Johnson, supra at 627-630.