Holden v. Owens-Illinois, Inc. Petitioner's Reply to the Brief in Opposition to Certiorari
Public Court Documents
January 1, 1986
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Brief Collection, LDF Court Filings. Holden v. Owens-Illinois, Inc. Petitioner's Reply to the Brief in Opposition to Certiorari, 1986. ea2d354f-b89a-ee11-be36-6045bdeb8873. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/102e0b19-2fbb-4916-b83b-1f3d921ad116/holden-v-owens-illinois-inc-petitioners-reply-to-the-brief-in-opposition-to-certiorari. Accessed May 17, 2025.
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No. 86-645
I n the
i>uprm t (Emtrt at % llmtib States
Octobeb Term, 1986
E. Marie H olden,
Owens-Illinois, I no.,
Petitioner,
Respondent.
PETITIONER’S REPLY TO THE BRIEF IN
OPPOSITION TO CERTIORARI
J ulius L. Chambers
Gail J . W right
J udith R eed*
Charles Stephen Ralston
99 Hudson Street
16th Floor
New York, New York 10013
(212) 219-1900
R obert B. Newman
Kircher and Phalen
Suite 1000
125 East Court Street
Cincinnati, Ohio 45202-1299
Attorneys for Petitioners
*Counsel of Record
No. 86-645
In The
SUPREME COURT OF THE UNITED STATES
October Term, 1986
E. MARIE HOLDEN,
Petitioner,
v .
OWENS-ILLINOIS, INC.
Respondent.
PETITIONER’S REPLY TO THE BRIEF IN
OPPOSITION TO CERTIORARI
Petitioner wishes to respond briefly
to the arguments made by the Respondent.
1. The respondent argues that the
Sixth Circuit's holding that a company is
free to discharge an employee because of
her efforts to obtain compliance by her
employer with Executive Order No. 11246
does not present an important question.
Petitioner, on the other hand, urges that
the decision below necessarily will
2
seriously interfere with the ability of
the federal government to enforce and
ensure compliance with the Executive
Order. Petitioner respectfully suggests
that it would be appropriate and useful
for the Court to request the Solicitor
General to file a brief expressing the
views of the United States on this
question.
2. Much of the respondent's brief
consists of an attempt to retry the facts
of this case before this Court. Thus, it
cites at length from the evidence it put
on at trial relating to whether the
Company had engaged in activities that
violated Title VII. Its presentation
ignores the fact that the district court
found against it based on the totality of
the evidence. 1 The attempt by respondent
1See the Appendix to the Petition at
pp. 31a - 32a; 39a.
to relitigate the case here is wholly
inappropriate and inconsistent with Rule
52a.
Respectfully submitted,
3
JULIUS L. CHAMBERS
GAIL J. WRIGHT
JUDITH REED*
CHARLES STEPHEN RALSTON
99 Hudson Street
16th Floor
New York, N.Y. 10013
(212) 219-1900
ROBERT B. NEWMAN
Kircher and Phalen
Suite 1000
125 East Court Street
Cincinnati, Ohio 45202-1299
Attorneys for Petitioners
♦Counsel of Record
Hamilton Graphics, Inc.— 200 Hudson Street, New York, N.Y.— (212) 966*4177