There’s no way I can get the “scoop” on what has been perhaps the most eagerly awaited Supreme Court decision of the term: Ricci v. DeStefano, No. 07-1428 (June 29, 2009).

Since the Court’s 5-4 decision was announced last week, it’s been the subject of a torrent of reporting and analysis, focused as much on its significance for the Supreme Court nomination of Judge Sonia Sotomayor — who was on the Court of Appeals panel the Supreme Court reversed — as for the difficult employment law issues with which it dealt.

So what can I possibly add?

My aim with this series of posts is to:

1. Present the complex and controversial facts, issues, and holding of Ricci in a digestible and comprehensible fashion, including key points made in the two concurring and one dissenting opinions — no mean feat given the 93-page length of the decision, including a 34-page majority opinion.
2. Point to some interesting commentary on the case.
3. Offer my own perspective, including practical implications for employers and their attorneys.

The series will be divided as follows:

• Part I: The basics: the facts and holding of the Ricci case
• Part II: The Ricci case majority opinion’s reasoning explained — what was and was not decided
• Part III: Interesting issues raised by the concurring and dissenting opinions in Ricci
• Part IV: Thoughts on the Ricci decision’s significance — my own and those of others

Ricci Case in a Nutshell

Ricci involved a race discrimination claim brought by white and Hispanic firefighters challenging the City of New Haven’s decision not to use certain test results for purposes of promoting firefighters to Captain and Lieutenant positions.

At the time of this decision by the City, many firefighters competing for the promotions, including the white and Hispanic plaintiffs, had studied for and taken the tests.

The City claimed it made this decision because using the tests would have exposed it to race discrimination liability due to the tests’ racially disproportionate impact on black applicants.

The Supreme Court crafted a new legal standard for this type of Catch-22 situation, in which either decision could arguably have exposed the City to discrimination liability.

Under this standard, the employer can use concerns about possible disparate-impact liability to defend a race-based decision only if it can demonstrate a strong basis in evidence that it would have been liable based on the disparate impact, rather than just a good faith concern about the risk of litigation over this issue or about the possibility of such liability.

Applying this standard, the Supreme Court reversed the summary judgment the district court had granted for the City, which the Court of Appeals had affirmed.

The Supreme Court held that the City had discriminated against the white and Hispanic firefighters and that the concern the City expressed about the disparate impact of the test did not justify the City’s decision.

Genesis of the Disputed New Haven Firefighters’ Exam

The City’s firefighter promotion process was restricted by two elements with which most private employers need not contend:

1. A civil service merit system requiring promotion of the most qualified individuals, as determined by job-related examinations, with each vacancy filled by one of the top three scoring applicants.
2. A firefighters’ union collective-bargaining agreement specifying further qualifications for promotion and requiring that 60% of the examination score be based on a written test and 40% on an oral test.

Given these requirements, the City contracted with a company that specializes in designing such nominations for fire and police departments — at a cost of $100,000.

This company took the following steps to customize-design an appropriate written and oral examination:

1. It conducted job analyses to identify the tasks, knowledge, skills, and abilities essential for the lieutenant and captain positions, using interviews, on-the-job observations, and questionnaires.
   • In this process, it deliberately oversampled minority lieutenants and captains in order to avoid any possible bias against minorities.
2. It compiled a list of training manuals, department procedures, and other materials to use as sources for test questions.
3. It used the source materials to draft a multiple-choice written test for each position.
4. It prepared oral examinations, concentrating on job skills and abilities identified by the job analyses and consisting of “hypothetical situations to test incident-command skills, firefighting tactics, interpersonal skills, leadership, and management ability, among other things.”
5. It assembled a pool of oral examiners:
   • These were “battalion chiefs, assistant chiefs, and chiefs from departments of similar sizes … throughout the country.”
   • 66% were minorities.
   • Each three-member oral examination panel contained two minority members.
   • Each oral examiner was trained for several hours to ensure consistent scoring.

Racially Disparate Impact of the Exam Results

In 2003, 118 New Haven firefighters took the examinations for promotion to lieutenant or captain.

The test results had a racially adverse impact. It was undisputed that this impact was significant and that it established a prima facie case of disparate-impact liability. The extent of the adverse impact was indicated by the pass rates:

On the captain exam:

• White: 64%
• Both black and Hispanic: 37.5%

On the lieutenant exam:

• White: 58.1%
• Black: 31.6%
• Hispanic: 20%

The minority pass rates fell well below the 80% standard set by the EEOC to implement the disparate-impact provision of Title VII, as they ranged from 34% to 59% of the white pass rates.

The City’s Conumdrum and Its Ill-Fated Decision

Based on the test scores and the “rule of three,” the City could not consider black candidates for any then-vacant lieutenant or captain position.

This led the mayor and other local politicians to “open a public debate that turned rancorous.” Some firefighters argued the tests should be discarded because the results showed them to be discriminatory. They threatened a discrimination lawsuit if the City used the tests.

Other firefighters said the exams were neutral and fair. They threatened a discrimination lawsuit if the City did not use the test.

Finding itself in this “damned if you do, damned if you don’t” conundrum, the City ultimately took the side of those who protested the test results, deciding not to use them. In making this decision, the City took the following steps:

1. Under the City’s contract with the company that prepared the tests, the company was to provide a technical report describing the testing process and analyzing its results. Instead of requesting this report, City officials met with the leader of the team that developed and administered the tests, who orally defended their validity.
2. Several days later, the City’s attorney stated in a letter to the Civil Service Board (”CSB”) that “a statistical demonstration of disparate impact,” standing alone, “constitutes a sufficiently serious claim of racial discrimination to serve as a predicate for employer-initiated, voluntar[y] remedies–even … race-conscious remedies.” This assertion, of dubious accuracy at best under then-existing federal law, became the issue ultimately decided by the Supreme Court.
3. A few weeks later, the CSB met and heard testimony from a number of witnesses, including a Department of Homeland Security fire programs specialist, an industrial/organizational (”I/O”) psychologist, the president of the New Haven firefighters’ union, and some firefighters. The City’s HR Director asked the CSB to discard the test results, citing the I/O psychologist’s statements about the possibility of alternative testing methods with less disparate impact. With one member recused, the CSB deadlocked, so there were insufficient votes to certify the test results.

Allegations of the White and Hispanic New Haven Firefighters’ Lawsuit

Some of the white and Hispanic firefighters who likely would have been promoted based on their test scores sued the City and some of its officials, alleging that by discarding the test results they discriminated against the plaintiffs based on race, in violation of both Title VII of the Civil Rights Act of 1964 and the Equal Protection Clause of the Fourteenth Amendment to the United States Constitution.

The City and its officials asserted the defense that use of the test results could have resulted in liability for adopting a practice with a racially disparate impact.

The Rulings Below Went Against the White and Hispanic New Haven Firefighters

The District Court granted summary judgment for the City and its officials, and a Court of Appeals panel affirmed without writing a detailed opinion.

This panel included Judge Sonia Sotomayor, now the President’s nominee to replace retiring Justice David Souter on the Supreme Court, adding further interest to the Ricci case.

In support of its conclusion that the City’s decision not to use the test results was not unlawful under either Title VII or the Equal Protection Clause, the District Court reasoned as follows:

• The argument against the City’s decision was that absent proof that the test-result disparities were caused by a particular flaw inherent in the exams, the City should have used the tests because there was no other alternative in place.
• However, the City was not obliged to use the test results simply because it had not yet formulated a better selection method.
• The “motivation to avoid making promotions based on a test with a racially disparate impact … does not, as a matter of law, constitute discriminatory intent” under Title VII.
• The Equal Protection claim lacked merit because there was no evidence of “discriminatory animus” toward the higher-scoring white and Hispanic firefighters.

The District Court’s bottom line was that the decision not to use the test scores was not “based on race” because “all applicants took the same test, and the result was the same for all because the test results were discarded and nobody was promoted.”

The Supreme Court’s Holding: The City Discriminated Against the Higher-Scoring White and Hispanic Candidates

The Supreme Court reversed the decision of the District Court, finding that the City had discriminated against higher scoring candidates. It said:

We conclude that race-based action like the City’s in this case is impermissible under Title VII unless the employer can demonstrate a strong basis in evidence that, had it not taken the action, it would have been liable under the disparate-impact statute.

The [City] … cannot meet that threshold standard. As a result, the City’s action in discarding the tests was a violation of Title VII. In light of our ruling under the statutes, we need not reach the question whether respondents’ actions may have violated the Equal Protection Clause.

More specifically, the Court stated:

[T]here is no evidence–let alone the required strong basis in evidence–that the tests were flawed because they were not job-related or because other, equally valid and less discriminatory tests were available to the City.

Fear of litigation alone cannot justify an employer’s reliance on race to the detriment of individuals who passed the examinations and qualified for promotions.

The City’s discarding the test results was impermissible under Title VII, and summary judgment is appropriate for petitioners on their disparate-treatment claim.

Next, in Part II: The Ricci case majority opinion’s reasoning explained — what was and was not decided.

Related Posts

1. Proving Discrimination: Back to Basics
2. Coca-Cola “cat’s paw” subordinate bias case dismissed on settlement week before Sup. Ct. arguments

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The summer project of my daughter Emily, who will be a senior in college this fall, it is funded by a grant from The Miller Center Vocations Initiative at Hendrix College, which “designs, funds and oversees a variety of programs created for the purpose of helping participants explore the content and nature of their life’s true calling.”

Wow! True calling? That’s a tall order. But Emily’s up for the challenge.

Swapping her past summers’ “vocation” of lifeguarding for modern e-journalism/blogging, she’s making the rounds with her digital recorder, interviewing what will surely be an interesting variety of people. She’s starting with people we know in our community, but hopes to extend outward from there.

Her blog posts based on these interviews will incorporate audio clips from the interviews, and perhaps also photos, which can provide a lively addition to the written content.

In addition to helping Emily explore the adult workworld, this project may be useful and of interest to her fellow college students and to career changers and counselors. I’d like to encourage my readers who have their own employment-related blogs to give the Vocations blog a mention and link.

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1. Do Interviews Work? If Not, What is the Alternative?

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photo credit: Tanel via flickr

Continuing my sixth-blog-anniversary observations about the changes I’ve seen in blogging and Internet content, and my own meandering personal journey as a blogger. Part I of this personal history of blogging is here.

Blogs, Web 2.0, and Information Overload — Making the Problem Better or Worse?

I originally saw bloggers as “web sherpas,” guiding a growing, loyal audience to the latest and coolest stuff on the web in a particular subject-matter niche, and doing so with a personal touch.

This sort of knowledge management and sharing purpose drove many of the earliest bloggers, whose style has been described as follows:

The original weblogs were link-driven sites. Each was a mixture in unique proportions of links, commentary, and personal thoughts and essays. … These were web enthusiasts.

Many current weblogs follow this original style. Their editors present links both to little-known corners of the web and to current news articles they feel are worthy of note. Such links are nearly always accompanied by the editor’s commentary.

An editor with some expertise in a field might demonstrate the accuracy or inaccuracy of a highlighted article or certain facts therein; provide additional facts he feels are pertinent to the issue at hand; or simply add an opinion or differing viewpoint from the one in the piece he has linked.

As an online legal researcher ever since the dial-up DOS days of the early 80s, I thought that through my passion for digging and reading online I’d do the heavy lifting for others who would regularly read my blog and marvel at the great web content I uncovered.

For a while, I actually thought I could stay on top of all the blogs in areas related to employment law and HR. As I saw more and more of them sprout up around me, I figured I could perhaps avoid getting lost in the shuffle, maintain a central position, and serve a useful function by serving up links, excerpts, and comments each Monday to the previous week’s best material by other bloggers.

I found myself spending significant weekend time preparing HR/Employment Blogosphere Update. But quickly the growth became so rapid I had to give up.

Today, you can still conveniently peruse the “HR/Employment Blogosphere” by yourself on my “Interactive Blogroll” (it may take a minute to load, it’s so full of relevant blogs).

The explosive growth of blogging leads me to wonder whether we all aren’t just making information overload much, much worse.

The flood of online content has become a tsunami.

I know I can’t possibly keep up with all the blogs in my blogroll — just one relatively narrow corner of the blogosphere!

But there’s another way to look at the problem. As user-created content has grown exponentially during the years I’ve been blogging, tools for searching, finding, organizing, following, and distributing it have also undergone drastic change and improvement.

The ultimate balance seems to be a much greater diversity of online content than during the pre-blog era, with an ever-increasing ability to obtain the specialized content one wants — when and where one wants it.

Search Engines, SEO, and RSS

Blogs Trump Conventional SEO

As I said in Part I of this series, shortly after I began blogging I discovered that search engines just love blogs.

That fact did not remain a secret for long, and it quickly became conventional wisdom that one of the best ways to create a website that would rank well in search, bringing free traffic, was to set it up as a blog or connect it to a blog.

Meanwhile, experts in search engine optimization (SEO) were charging thousands of bucks to engage in all sorts of legitimate and illegitimate manipulation of conventional websites that would increase search traffic. But plain-Jane blogs with lots of good content, frequently updated, often beat out costly SEO efforts.

Blogs Have to Use SEO Techniques to Keep Up

Then the field started to become so crowded that this was no longer enough. It wasn’t as simple as beating out static websites simply by having a blog — not when hundreds of blogs started showing up in search results.

Now it wasn’t just static website owners vs. bloggers; it was bloggers vs. bloggers. Smart SEO practices became essential in order for a blog to pull down the most search traffic. And the name of the game became “how to get free traffic to your blog.”

RSS Solves Information Overload — Kind Of

Meanwhile, RSS exploded onto the scene, seeming to promise the next great great solution to information overload.

Blogs had initially seemed a solution to this problem — relative to simply searching the web, as I mentioned above — but now their incredible proliferation had simply made matters worse. We went from “too much web content, too little time” to “a few great blogs point me to all the best web content” to “too many blogs, too little time” — all in the space of a year or two.

RSS and aggregators like bloglines promised to allow review of “hundreds of stories and blog entries in less than half the time it would take using a browser and a favorites list.”

Well, I started using Bloglines and pretty soon clogged it up with so many feeds I had — you guessed it — information overload! “Too many RSS feeds, too little time!”

Nonetheless, RSS is a great thing. Used with a bit of moderation, it can create great at-a-glance customized personal news pages, for example, and blogs and websites can use it to create newsfeed widgets.

Social Bookmarking — The Next Big Thing

As I fell further and further behind in my efforts to stay on top of and blog about all kinds of interesting online reading connected with the subjects of this blog — despite RSS — along came the social bookmarking sites.

I found these exciting because they allowed me to at least preserve and “tag” (assign keywords to) items of interest — and access these bookmarks from any computer (in contrast to regular bookmarks stored on an individual computer’s browser).

I chose to use delicious. Lo and behold, delicious creates RSS feeds for every tag, so I could create topical feeds for display on my blog just by using topical tags.

They now appear under “George’s Micro-Blogs” at right. And you can subscribe to them here.

Many other ways for busy websurfers to organize their information and combat information overload (or at least information clutter) come online frequently.

Just the other day, I discovered another one to try: iLighter, which uses a highlighter and “sticky note” approach, combined with a flexible foldering system for storing not just links, but also excerpts from web pages.

In Part III: Different visions of blogs and blogging, trying to monetize the blog, shifting subject matter over time, and more….

Additional Resources

• Roundtable by four long-time St. Louis blogging lawyers (including me): A Blogging Guide for St. Louis (and Other) Lawyers (and Others)
• Internet Resources on Information Overload and Productivity
• Beating Information Overload with News Aggregators
• Master Your Information Manifesto: 21 Tips to Deal with Info Overload
• Social Bookmarking Apps Provide a New Knowledge Management Platform

Related Posts

1. Celebrating Six Years of Blogging — How the Online World Has Changed! (Part I)
2. Pros and Cons of Company-Sponsored Blogging
3. Blogging About Blogging: Always a Formula for Success (Blawg Review #125 @ Kevin O’Keefe’s “Real Lawyers Have Blogs”)

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photo credit: Tanel via flickr

Birth of a Blog (Blawg)

A bit over six years ago (on May 12, 2003, to be precise) I stumbled out into the blogosphere, then in its infancy, with a short post explaining my humble purpose in becoming a blogger:

Most days I read recent cases and material on labor and employment law. But too often, by the time I need to cite a case or whatever, I’ve forgotten what I read and can’t find it. So one purpose of this is to have my own personal archive. While I’m at it, why not share it with the world?

Simple enough. I’d use my new Blogger account in the original sense of a “weblog” — to save links and excerpts of cases and articles. It would be like a personal electronic clippings file.

I figured if I really wanted others reading my blog, I’d have to undertake some kind of publicity and link-building campaign. My simplistic understanding of Google prominence was that it required lots of carefully cultivated inbound links.

Less than three months after starting this blog, I found out I had been wrong — my Internet visibility was much higher than I had imagined. I got the following e-mail:

I’m a staff writer for Workforce Management Magazine and I’m doing an article about H.R. blogs. Can I interview you?

How did that happen? I didn’t think anyone knew about my blog! Turns out he had just done a Google search, and Google was giving blogs great search rankings. I conjectured this was because along with inbound links, frequent updating and quality content were key factors in the magic (and secret) Google popularity formula.

So with that confirmation that I actually was sharing my blog with the world, I was hooked.

I’m honoring this personal blog-anniversary with a series of posts containing some personal observations about the changes I’ve seen in blogging and Internet content throughout these six years, and about my own meandering personal journey as a blogger.

Such reflection and reminiscence is my privilege as such an old-timer, I suppose — and more famous, more venerable bloggers have done similarly. E.g., Robert Scoble and Rebecca Blood, the latter already looking backwards as an experienced blogger when she wrote a fascinating retrospective on blogging way back in September 2000.

And, in any event, periodic rambling, thinking-out-loud writing is my privilege as a blogger answerable to no one — the very editorial freedom that is one of the huge attractions, and possible perils, of blogging.

Status of Blogs and Bloggers

When I started blogging, most people to whom I mentioned this new activity obsession of mine had never heard of a blog or blogger. Even a verbal explanation left many uncomprehending. Today, these terms are commonplace and well understood by virtually everyone I encounter.

“Blog” is in many dictionaries, as it should be. Same with “blogger. “While bloggers are sometimes referred to with derision or ridicule, at least as often status as a blogger is viewed as a badge of expertise, such as:

• When I’m driving home listening to NPR and hear a “Bloggers’ Roundtable“
• When I read a quote in Newsweek by law professor Steven Davidoff, “perhaps better known by his nom de blog: the Deal Professor.”
• When I see on TV that a celebrity blogger with a Google Page Rank 7 site, major corporate advertising, and a name confusingly similar to a hot hotel heiress has flamboyantly added a litmus test on gay marriage to the Miss America pageant requirements.

Back in 2003, it would have seemed delusional to predict that in a mere six years:

• Conventional print journalism would be on the ropes, fighting for survival.
• Bloggers would appear to many to be the “new journalists.”
• Many newspapers and magazines would be creating their own blogs.
• Some bloggers would be migrating the other way — from Internet to print.

But here we are!

Functional Evolution of Blogs From Casual Personal Expression to Corporate and Marketing Tool

Initially, many viewed blogs as nothing more than frivolous, narcissistic personal journals. Who, people wondered, really wanted to read about what you had for breakfast? [click link for a great Web 2.0 photo-cartoon.]

When a critical mass of lawyers started blogging on serious legal topics, and other professions began doing likewise, it signaled the evolution of a business-oriented segment standing in contrast to the blogs that featured everyday personal content, though some early blawgs kept a light and personal touch while they led and observed this expansion of the legal blogosphere.

Soon, along came advocates of blogging-as-marketing and blogging-as-cool-corporate-communications. Businesses large and small joined the party, including increasing numbers of law firms (as opposed to individual renegade bloggers like me). Some began paying consultants and writers to build and maintain blogs.

And I soldiered along, just trying to continue posting good content that not only summarized and linked to others’ work, but also always provided some added value.

In Part II: Blogging meets information overload, SEO, RSS, social bookmarking and more….

Additional Blogging History Resources

• Roundtable by four long-time St. Louis blogging lawyers (including me): A Blogging Guide for St. Louis (and Other) Lawyers (and Others)
• Weblogs: a History and Perspective, Rebecca Blood, (September 7, 2000)
• History of Blogging Timeline, wikipedia
• The Early Years [of Blogging -- 1994-2006], New York Magazine

Related Posts

1. Celebrating Six Years of Blogging — How the Online World Has Changed! (Part II)
2. Blogging About Blogging: Always a Formula for Success (Blawg Review #125 @ Kevin O’Keefe’s “Real Lawyers Have Blogs”)
3. Why Blogging Is GOOD For Your Career (Unless You Are Fired!)

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photo credit: Athena's Pix via flickr

This is the third in a series of guest posts on green jobs by Alexia Vernon, a leadership and career speaker, certified coach, trainer, and writer with an expertise in social enterprise and millennials.

Previous Posts in Series

Part I of this green jobs series was a general introduction to the topic and Part II explored several green job fields and some specific opportunities within each.

Top 10 Websites for Green Job Seekers

1. Green Jobs Network
   GJN features opportunities in clean energy and tech, climate change, natural resource management, renewable energy, and green building.
2. Green Dream Jobs at SustainableBusiness.com
   This website covers a broad range of green fields with an emphasis on business (e.g. corporate social responsibility (CSR), environmental social responsibility (ESR), socially responsible investing, and consulting), but also including such areas as policy and land use, clean energy, and natural resources and restoration.
3. Green Job List
   This listserv offers an array of opportunities in environmental science and social responsibility.
4. GreenBiz.com Career Center
   GreenBiz.com specializes in jobs in renewable energy, clean technology, green building, sustainable business, design and innovation.
5. Jobs for Change
   One of my favorites, this subdivision of change.org focuses on jobs that make a positive social impact both in the private and nonprofit sectors. Make sure to check out the stellar blogs of its various career advisors.
6. Common Good Careers
   CGC features jobs across nonprofits and educational institutions that enable socially conscious professionals to make a positive social impact through their employment.
7. Idealist.org
   An oldie but a goodie, Idealist focuses on nonprofit opportunities, government jobs, and consulting positions that build a better, more equitable world. Also, check out their new book — The Idealist.org Handbook for Building a Better World
8. Young Nonprofit Professionals Network
   This membership organization has chapters in close to a dozen U.S. cities (and the same number in the works) and a free listserv that frequently has nonprofit green and social-change-oriented jobs, educational events, and networking opportunities.
9. Net Impact
   To access Net Impact’s Career Center, one must be a member. And it’s well worth it. Net Impact is a global network of leaders looking to change the world through business. With chapters around the world, multiple yearly international conferences, monthly “Issues in Depth” calls, and job listings, educational opportunities, and fellowships at the intersections of business, sustainability, and social change, MBAs take note. This is where you want to be hanging out.
10. Aerotek
    Aerotek is a nationwide staffing service with an expertise in engineering and environmental job placement.

Some Outside-the-Box Ideas For Finding Green Jobs

While bookmarking each of these sites and checking in weekly will keep you in “the know,” remember that only approximately 5% of jobs are posted online. The other 95% are secured through connections. The good news is that you will encounter hundreds of job possibilities from the resources above even though you will just be skimming the surface.

Go beyond that, and tap into the other 95%, by proving to yourself and to prospective employers that you have a sustainable mindset — don’t just think outside the box when it comes to the job hunt, but recycle the darn box. For example:

• Many of the previously mentioned organizations and sites have LinkedIn groups. Join them, connect with other members (particularly those who are in HR and management or have hundreds of contacts in your desired field, and request informational interviews from them.
• Follow the people you find in the groups and the groups themselves on Twitter.
• Share articles, blog posts, questions, and ideas you think they will find valuable. Build yourself a web presence as a green citizen and create the possibility for green opportunities to find you.

About guest poster Alexia Vernon:

Alexia Vernon is a leadership and career speaker, certified coach, trainer, and writer with an expertise in millennials and social enterprise.

As the owner of Catalyst for Action, Alexia empowers values-driven leaders to harness their values, strengths, enthusiasms, and resources to build careers and companies that achieve the 3 S’s: success, sustainability, and a positive social impact.

Alexia’s blog, Musings from the Generation We Coach is on Blogs.com’s “10 Blogs to Read If You’ve Just Been Laid Off”, and she is the Newark Corporate Leadership Examiner. Follow her on Twitter and contact her by email at alexia@alexiavernon.com for a complimentary, telephone career coaching session.

Related Resources

From Our Bookstore

• Green Jobs: A Guide to Eco-Friendly Employment
• Careers in Renewable Energy: Get a Green Energy Job
• Saving the Earth as a Career: Advice on Becoming a Conservation Professional
• The ECO Guide to Careers that Make a Difference: Environmental Work For A Sustainable World
• 75 Green Businesses You Can Start to Make Money and Make A Difference
• More books on Environmental & Green Jobs

Related Articles

• Time Magazine: What Is a Green-Collar Job, Exactly?
• LA Times: Why Obama’s Green Jobs Plan Might Work
• In These Times: Green Jobs for Whom?
• Green for All: Green-Collar Jobs Overview
• How Stuff Works: What are Green-Collar Jobs?

Related Posts

1. Green Jobs: What They Are and Where to Look for Them, Part I
2. Green Jobs: What They Are and Where to Look for Them, Part II

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