Golden Gate University Law Review


Theresa Marks


This note discusses the guidelines established in Johnson. It will suggest that under the Johnson standards, general societal discrimination may provide a sufficient basis for imposing voluntary, sexually classified remedies under Title VII It will further suggest that voluntary affirmative action in response to general societal discrimination is consistent with the United States Supreme Court's interpretation of Congress's intent in enacting Title VII Finally, this note will evaluate the potential benefit the Johnson decision brings to women's rights as well as noting the problems presented by the Court's failure to clearly delineate appropriate standards for affirmative action.