The Court of Appeals for the Third Circuit held that an action seeking relief from racial discrimination by a private employer based on the Civil Rights Act of 1866 is not impliedly barred by Title VII of the Civil Rights Act of 1964.
Young v. International Telephone and Telegraph Company, 438 F.2d 757 (3d Cir. 1971).
Mark J. Zovko Jr.,
Labor Law - Racial Discrimination in Employment - Reconciliation of the Policies of Title VII of the Civil Rights Act of 1964 with the Civil Rights Act of 1866,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol10/iss3/11