Title VII of the Civil Rights Act of 1964 grants the federal courts jurisdiction in employment discrimination matters and sanctions orders of affirmative relief where equitable. This relief, usually in the form of back pay and injunctions, may be awarded upon a finding of intentional, discriminatory labor practices. Being equitable remedies, however, the courts have given numerous and conflicting interpretations as to when such affirmative relief should be awarded or denied. The prior history of Albemarle Paper Co. v. Moody typifies the inconsistencies in this area. The case was a class action under Title VII by former and present employees of Albemarle Paper Company. The class, after following the designated administrative procedures, filed for an injunction against Albemarle's alleged unlawful employment practices. Backpay was not requested until after several years of discovery and motions. The allegations attacked the company's seniority system and its requirement of a high school diploma and passing of two tests for entry into the skilled production lines.