Preceding the passage of the Civil Rights Act, Duke had a policy of segregating employees based on their race. Historically, African-Americans were only allowed to work as laborers at the Dan River Plant in Draper North Carolina. Laborers were the lowest-paying positions at the facility. After the Civil Rights Act was passed in 1964, Duke updated the policy pertaining to the case by mandating that most employees have either a high school diploma or a minimum IQ for all positions other than laborers. Duke Power never