# Johnson v. Transportation Agency
*Supreme Court of the United States decision (1987), cited in the project's claim rows as precedent in challenges to Minn. Stat. § 43A.191.*
*Johnson v. Transportation Agency*, 480 U.S. 616, is a decision of the Supreme Court of the United States reported in 1987.[^1] Three of the project's validated claim:link rows cite it, each under a different legal theory against [[Minn. Stat. § 43A.191]], the [[Minnesota]] statute whose subdivision 3(c) requires an agency to explain the reason for hiring a non-affirmative candidate.[^2][^3][^4][^5]
Each of the three rows names *Johnson* as the precedent under which a decision the rows call *Maitland* found § 43A.191 unlawful. One row says *Maitland* "proved" it unlawful.[^2] Another calls the case controlling [[Title VII]] precedent.[^3] None of the sources cited here includes the *Maitland* decision. That finding is therefore reported as the claim rows state it. These sources do not establish it.[^4]
On January 14, 2026, the United States sued the State under Title VII in [[United States v. State of Minnesota (0:26-cv-00273)]].[^5] The [[United States Department of Justice]] announced the suit in release No. 26-21, titled *United States Department of Justice Files Lawsuit Against Minnesota's 'Affirmative Action' Regime*.[^6] The sources cited here do not show whether the complaint cites *Johnson*.
## What
The decision appears under the reporter citation 480 U.S. 616 (1987).[^1] The sources cited here do not include the text of its holding. Within this record, the case is used only through the project's claim rows:
- Under Theory 1 (Title VII disparate treatment / § 43A.191), the row describes *Johnson* as the Supreme Court precedent under which *Maitland* proved § 43A.191 unlawful.[^2]
- Under Theory 4 (Fourteenth Amendment equal protection), the row describes it as controlling Title VII precedent under which *Maitland* found "the §43A.191 architecture" unlawful.[^3]
- Under Theory 5 (42 U.S.C. § 1981), the row describes it as controlling Title VII and equal-protection precedent under which *Maitland* found § 43A.191 unlawful.[^4]
Claim:link rows rank below filed court documents, agency releases and statute text. No court document among the cited sources states the *Maitland* finding.[^2]
## When
- 1987: the Supreme Court decides *Johnson v. Transportation Agency*, 480 U.S. 616.[^1]
- 2025: the Supreme Court decides *[[Ames v. Ohio Department of Youth Services]]*, 605 U.S. 303.[^7]
- January 14, 2026: the United States files *United States v. State of Minnesota*, No. 0:26-cv-00273 (D. Minn.). The Department of Justice issues release No. 26-21 on the same day.[^5][^6]
## Who
The Supreme Court of the United States decided *Johnson*.[^1] The 2026 complaint was filed by the Department of Justice's Civil Rights Division.[^5] Attorney General Pamela Bondi certified the case as a matter of general public importance.[^6]
The title of release No. 26-21 uses the phrase "Minnesota's 'Affirmative Action' Regime" for the State's apparatus.[^6] The [[Iraq Liberation Act]] of 1998 (Pub. L. 105-338) states a policy of supporting efforts to remove "the regime headed by Saddam Hussein."[^8] The project's catalogue of U.S.-government "regime" usages ([[How Minnesota Got Here]], note 40) finds Minnesota the only U.S. state so described. That is the catalogue's finding, not an independently established fact.
## How
The United States' complaint is brought under Title VII of the [[Civil Rights Act of 1964]].[^5] It cites Minn. Stat. § 43A.191 eight times. Those citations include subd. 3(c)'s requirement that an agency explain the reason for hiring a non-affirmative candidate.[^5] The sources cited here record the filing but no later status of the case.[^5][^6]
The pinned framing also places a recent Title VII decision beside the case. In *Ames v. Ohio Department of Youth Services*, 605 U.S. 303 (2025), the Supreme Court held that Title VII's disparate-treatment provision "draws no distinctions between majority-group plaintiffs and minority-group plaintiffs."[^7] It rejected the Sixth Circuit's heightened "background circumstances" rule for majority-group plaintiffs.[^7]
## How many
- 3: validated claim:link rows that cite *Johnson*. They fall under Theories 1, 4 and 5 of the project's 14 legal theories.[^2][^3][^4]
- 8: citations of Minn. Stat. § 43A.191 in the United States' complaint, No. 0:26-cv-00273.[^5]
## Notes
[^1]: Supreme Court of the United States, *Johnson v. Transportation Agency*, 480 U.S. 616 (1987) — reporter citation and year of decision (Justia reporter entry). https://supreme.justia.com/cases/federal/us/480/616/
[^2]: How Minnesota Got Here, *Validated claim:link pair 27, Theory 1 — Title VII Disparate Treatment / §43A.191* (undated) — describes *Johnson* as the precedent under which *Maitland* proved § 43A.191 unlawful; links the reporter entry. https://supreme.justia.com/cases/federal/us/480/616/
[^3]: How Minnesota Got Here, *Validated claim:link pair 45, Theory 4 — Fourteenth Amendment Equal Protection* (undated) — describes *Johnson* as controlling Title VII precedent under which *Maitland* found the § 43A.191 architecture unlawful; links the reporter entry. https://supreme.justia.com/cases/federal/us/480/616/
[^4]: How Minnesota Got Here, *Validated claim:link pair 55, Theory 5 — 42 U.S.C. §1981* (undated) — describes *Johnson* as controlling Title VII / Equal Protection precedent under which *Maitland* found § 43A.191 unlawful; links the reporter entry. https://supreme.justia.com/cases/federal/us/480/616/
[^5]: U.S. Department of Justice, Civil Rights Division, *Complaint, United States v. State of Minnesota*, No. 0:26-cv-00273 (D. Minn. filed Jan. 14, 2026) — brought under Title VII; cites Minn. Stat. § 43A.191 eight times, including subd. 3(c). https://www.justice.gov/crt/media/1423361/dl
[^6]: U.S. Department of Justice, Office of Public Affairs, *United States Department of Justice Files Lawsuit Against Minnesota's 'Affirmative Action' Regime*, release No. 26-21 (Jan. 14, 2026) — announces the suit; Attorney General Pamela Bondi certified the case as a matter of general public importance. https://www.justice.gov/opa/pr/united-states-department-justice-files-lawsuit-against-minnesotas-affirmative-action-regime
[^7]: Supreme Court of the United States, *Ames v. Ohio Department of Youth Services*, 605 U.S. 303 (2025) — holds that Title VII's disparate-treatment provision draws no distinction between majority- and minority-group plaintiffs; rejects the "background circumstances" rule. https://www.supremecourt.gov/opinions/24pdf/23-1039_c0n2.pdf
[^8]: United States Congress, *Iraq Liberation Act of 1998*, Pub. L. 105-338 (1998) — states the policy of supporting efforts to remove "the regime headed by Saddam Hussein." https://www.govinfo.gov/content/pkg/PLAW-105publ338/pdf/PLAW-105publ338.pdf