Disparate impact or unintentional discrimination occurs when a racially neutral employment practice has the effect of disproportionately excluding a group based upon a protected category. The Supreme Court expanded the definition of illegal discrimination in 1971 to include disparate impact I the case of Griggs v. Duke Power Co. Willie Griggs was an applicant for a job as a coal handler at the Duke Power Company. Duke required coal handlers to be high school graduates and receive a satisfactory score on two aptitude tests. Griggs claimed that these requirements were unfairly discriminatory in that they resulted in a disproportionate number of African Americans being disqualified and were not related to the job. In ruling for Griggs, the Supreme Court held that Duke failed to demonstrate that the selection criteria were fob-related.