The Court also examined whether Test 21 had a discriminatory effect. After applying the disparate impact analysis, it held that Test 21 did not have a discriminatory effect on blacks. The Court held that the Court of Appeals had erroneously assumed that the stricter, effects-based "disparate impact" test, under Title VII of the Civil Rights Act of 1964, existed under the Constitution's Equal Protection Clause as well. The Court pointed out that the Washington, DC, police department had gone to significant lengths to recruit black officers. In the years since the case was brought before the trial court, the ratio of blacks on the police force to blacks in the community had nearly evened out.