When Congress passed the Civil Rights Act of 1964, the actual law was the result of major compromises between Southern Democrats, who controlled most of the committee structure of Congress, and more liberals Democrats and Republicans. In looking at Title VII, governing employment relationships, we can see that the intent of Congress was to have the law outlaw 'individual discrimination', which we have labeled "disparate treatment". Several years later, the U.S. Supreme Court heard a case called Griggs vs. Duke Power. In reaching their decision, the Court imposed a standard called "disparate impact", which is quite different. Discuss the Court's use of this new standard, and its impact on enforcement of Title VII.