Narrative Opinion Summary
In this case, appellants of Ethiopian, Yemeni, and Jordanian descent alleged racial discrimination under 42 U.S.C. § 1981 after Fred Meyer, Inc. refused to sell them Levi's jeans. They claimed this was due to their race, while Fred Meyer argued the refusal was based on Levi Strauss & Co.'s policy against selling to resellers, which the appellants admitted to being. The district court granted summary judgment to Fred Meyer, finding legitimate, nondiscriminatory reasons for its actions, and the appellants could not prove discrimination pretext. Additionally, claims under 42 U.S.C. § 1985(3) were dismissed for lack of evidence of discriminatory intent. The court also held that attempts to enter contracts via misrepresentation do not constitute cognizable injuries under Section 1981. Some claims were barred by the statute of limitations. The appellate court affirmed the summary judgment on most claims but reversed it on two claims related to the return of merchandise, allowing further proceedings, with each party bearing its own costs.
Legal Issues Addressed
Application of 42 U.S.C. § 1981 in Retail Transactionssubscribe to see similar legal issues
Application: The case examines whether refusal to sell merchandise based on reseller status constitutes a violation under 42 U.S.C. § 1981, which ensures equal contractual rights.
Reasoning: The legal analysis centers on Section 1981, which ensures all U.S. citizens the same contractual rights as white citizens, prohibiting both governmental and private discrimination in contract matters.
Conspiracy Claims under 42 U.S.C. § 1985(3)subscribe to see similar legal issues
Application: The court dismissed claims under § 1985(3) due to lack of evidence of racial or class-based discriminatory intent.
Reasoning: An essential element for a claim under 42 U.S.C. § 1985(3) is the presence of a racial or class-based discriminatory animus behind the alleged conspirator's actions, as established in Griffin v. Breckenridge.
Misrepresentation and Voidable Contracts under Section 1981subscribe to see similar legal issues
Application: The court found that attempts to enter contracts based on misrepresentation do not constitute an injury under Section 1981.
Reasoning: The document asserts that the attempted purchase of Levi's, given the misrepresentation of their status, constituted an attempt to enter a voidable contract, which does not amount to a cognizable injury under Section 1981.
Retailer Policies and Reseller Restrictionssubscribe to see similar legal issues
Application: Fred Meyer's policy to limit sales to individual consumers was upheld as a legitimate business practice under the terms set by Levi Strauss.
Reasoning: Fred Meyer must adhere to Levi Strauss policies as a condition of selling Levi's products, which limits sales to two pairs per customer and prohibits sales to individuals suspected of being resellers.
Statute of Limitations in Section 1981 Claimssubscribe to see similar legal issues
Application: Claims by appellant Hemdeh were barred by the statute of limitations, as they were filed beyond the permissible two-year period.
Reasoning: These claims are barred by Oregon's two-year statute of limitations, as Hemdeh filed his original complaint on July 21, 1997, and was added as a plaintiff on October 14, 1997.
Summary Judgment Standards in Discrimination Casessubscribe to see similar legal issues
Application: Summary judgment was granted as Fred Meyer provided a legitimate, nondiscriminatory reason for refusal to sell, and appellants failed to show pretext.
Reasoning: The district court granted summary judgment for Fred Meyer, applying the disparate treatment test from Title VII of the Civil Rights Act.