Case 20.2 Ricci v. Destefano New Haven, Conn. (City), uses objective examinations to identify those firefighters best qualified for promotion. When the results of such an exam to fill vacant lieutenant and captain positions showed that white candidates had outperformed minority candidates, a rancorous public debate ensued. Confronted with arguments both for and against certifying the test results—and threats of a lawsuit either way—the City threw out the results based on the statistical racial disparity. Petitioners, white and Hispanic firefighters who passed the exams but were denied a chance at promotions by the City’s refusal to certify the test results, sued the City and respondent officials, alleging that discarding the test results discriminated against them based on their race in violation of, inter alia, Title VII of the Civil Rights Act of 1964. The defendants responded that had they certified the test results, they could have faced Title VII liability for adopting a practice having a disparate impact on minority firefighters. The District Court granted summary judgment for the defendants, and the Second Circuit affirmed. Justice Sotomayor was on the Second Circuit at the time of that decision. Justice Kennedy wrote the majority opinion in which Chief Justice Roberts, and Justices Scalia, Thomas and Alito joined. Justice Ginsburg filed a dissenting opinion in which Justices Stevens, Souter and Breyer joined. In her dissent, Justice Ginsburg notes that firefighting is “a profession in which the legacy of racial discrimination casts an especially long shadow” and that the facts of this case should be assessed “against this backdrop of entrenched inequality.” KENNEDY, J.: In the fire department of New Haven, Connecticut—as in emergency-service agencies throughout the Nation—firefighters prize their promotion to and within the officer ranks. An agency’s officers command respect within the department and in the whole community; and, of course, added responsibilities command increased salary and benefits. Aware of the intense competition for promotions, New Haven, like many cities, relies on objective examinations to identify the best-qualified candidates. In 2003, 118 New Haven firefighters took examinations to qualify for promotion to the rank of lieutenant or captain. Promotion examinations in New Haven (or City) were infrequent, so the stakes were high. The results would determine which firefighters would be considered for promotions during the next two years, and the order in which they would be considered. Many firefighters studied for months, at considerable personal and financial cost. When the examination results showed that white candidates had outperformed minority candidates, the mayor and other local politicians opened a public debate that turned rancorous. Some firefighters argued the tests should be discarded because the results showed the tests to be discriminatory. They threatened a discrimination lawsuit if the City m ...

1. Case 20.2 Ricci v. Destefano
New Haven, Conn. (City), uses objective examinations to
identify those firefighters best qualified for promotion. When
the results of such an exam to fill vacant lieutenant and captain
positions showed that white candidates had outperformed
minority candidates, a rancorous public debate ensued.
Confronted with arguments both for and against certifying the
test results—and threats of a lawsuit either way—the City threw
out the results based on the statistical racial disparity.
Petitioners, white and Hispanic firefighters who passed the
exams but were denied a chance at promotions by the City’s
refusal to certify the test results, sued the City and respondent
officials, alleging that discarding the test results discriminated
against them based on their race in violation of, inter alia, Title
VII of the Civil Rights Act of 1964. The defendants responded
that had they certified the test results, they could have faced
Title VII liability for adopting a practice having a disparate
impact on minority firefighters. The District Court granted
summary judgment for the defendants, and the Second Circuit
affirmed. Justice Sotomayor was on the Second Circuit at the
time of that decision. Justice Kennedy wrote the majority
opinion in which Chief Justice Roberts, and Justices Scalia,
Thomas and Alito joined.
Justice Ginsburg filed a dissenting opinion in which Justices
Stevens, Souter and Breyer joined. In her dissent, Justice
Ginsburg notes that firefighting is “a profession in which the
legacy of racial discrimination casts an especially long shadow”
and that the facts of this case should be assessed “against this
backdrop of entrenched inequality.”
KENNEDY, J.: In the fire department of New Haven,
Connecticut—as in emergency-service agencies throughout the

2. Nation—firefighters prize their promotion to and within the
officer ranks. An agency’s officers command respect within the
department and in the whole community; and, of course, added
responsibilities
command increased salary and benefits. Aware of the intense
competition for promotions, New Haven, like
many cities, relies on objective examinations to identify the
best-qualified candidates. In 2003, 118 New
Haven firefighters took examinations to qualify for promotion
to the rank of lieutenant or captain. Promotion
examinations in New Haven (or City) were infrequent, so the
stakes were high. The results would determine which
firefighters would be considered for promotions during the next
two years, and the order in which they would be considered.
Many firefighters studied for months, at considerable personal
and financial cost.
When the examination results showed that white candidates had
outperformed minority candidates, the mayor and other local
politicians opened a public debate that turned rancorous. Some
firefighters argued the tests should be discarded because the
results showed the tests to be discriminatory. They threatened a
discrimination lawsuit if the City made promotions based on the
tests. Other firefighters said the exams were neutral and fair.
And they, in turn, threatened a discrimination lawsuit if the
City, relying on the statistical racial disparity, ignored the test
results and denied promotions to the candidates who had
performed well. In the end the City took the side of those who
protested the test results. It threw out the examinations.
Certain white and Hispanic firefighters who likely would have
been promoted based on their good test performance sued the
City and some of its officials. Theirs is the suit now before us.
The suit alleges that, by discarding the test results, the City and
the named officials discriminated against the plaintiffs based on
their race, in violation of both Title VII of the Civil Rights Act

3. of 1964, 78 Stat. 253, as amended, 42 U. S. C. §2000e et seq.,
and the Equal Protection Clause of the Fourteenth Amendment.
The City and the officials defended their actions, arguing that if
they had certified the results, they could have faced liability
under Title VII for adopting a practice that had a disparate
impact on the minority firefighters. The District Court granted
summary judgment for the defendants, and the Court of Appeals
affirmed. 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 respondents, we further determine, 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. . . .
Title VII of the Civil Rights Act of 1964, 42 U. S. C.§2000e et
seq., as amended, prohibits employment discrimination on the
basis of race, color, religion, sex, or national origin. Title VII
prohibits both intentional discrimination (known as “disparate
treatment”) as well as, in some cases, practices that are not
intended to discriminate but in fact have a disproportionately
adverse effect on minorities (known as “disparate impact”). . . .
The Civil Rights Act of 1964 did not include an express
prohibition on policies or practices that produce a disparate
impact. But in Griggs v. Duke Power Co., 401 U. S. 424 (1971),
the Court interpreted the Act to prohibit, in some cases,
employers’ facially neutral practices that, in fact, are
“discriminatory in operation.” Id., at 431. The Griggs Court
stated that the “touchstone” for disparate impact liability is the
lack of “business necessity”: “If an employment practice which
operates to exclude [minorities] cannot be shown to be related
to job performance, the practice is prohibited.” . . . Twenty
years after Griggs, the Civil Rights Act of 1991, 105 Stat. 1071,

4. was enacted. The Act included a provision codifying the
prohibition on disparate-impact discrimination. That provision
is now in force along with the disparate-treatment section
already noted. Under the disparate-impact statute, a plaintiff
establishes a prima facie violation by showing that an employer
uses “a particular employment practice that causes a disparate
impact on the basis of race, color, religion, sex, or national
origin.” 42 U. S. C. §2000e–2(k)(1)(A)(i). An employer may
defend against liability by demonstrating that the practice is
“job related for the position in question and consistent with
business necessity.” Ibid. Even if the employer meets that
burden, however, a plaintiff may still succeed by showing that
the employer refuses to adopt an available alternative
employment practice that has less disparate impact and serves
the employer’s legitimate needs. . . . Petitioners allege that
when the CSB refused to certify the captain and lieutenant exam
results based on the race of the successful candidates, it
discriminated against them in violation of Title VII’s disparate-
treatment provision. The City counters that its decision was
permissible because the tests “appear[ed] to violate Title VII’s
disparate impact provisions.” . . . The same interests are at work
in the interplay between the disparate-treatment and disparate-
impact provisions of Title VII. Congress has imposed liability
on employers for unintentional discrimination in order to rid the
workplace of “practices that are fair in form, but discriminatory
in operation.” Griggs, supra, at 431. But it has also prohibited
employers from taking adverse employment actions “because
of” race. §2000e–2(a)(1). Applying the strong-basis-in evidence
standard to Title VII gives effect to both the disparate-treatment
and disparate-impact provisions, allowing violations of one in
the name of compliance with the other only in certain, narrow
circumstances. The standard leaves ample room for employers’
voluntary compliance efforts, which are essential to the
statutory scheme and to Congress’s efforts to eradicate
workplace discrimination. And the standard appropriately
constrains employers’ discretion in making race-based

5. decisions: It limits that discretion to cases in which there is a
strong basis in evidence of disparate-impact liability, but it is
not so restrictive that it allows employers to act only when there
is a provable, actual violation.
Resolving the statutory conflict in this way allows the
disparate-impact prohibition to work in a manner that is
consistent with other provisions of Title VII, including the
prohibition on adjusting employment- related test scores on the
basis of race. . . . The racial adverse impact here was
significant, and petitioners do not dispute that the City was
faced with a prima facie case of disparate-impact liability. On
the captain exam, the pass rate for white candidates was 64
percent but was 37.5 percent for both black and Hispanic
candidates. On the lieutenant exam, the pass rate for white
candidates was 58.1 percent; for black candidates, 31.6 percent;
and for Hispanic candidates, 20 percent. The pass rates of
minorities, which were approximately one half the pass rates for
white candidates, fall well below the 80-percent standard set by
the EEOC to implement the disparate-impact provision of Title
VII. . . .
There is no genuine dispute that the examinations were job-
related and consistent with business necessity.
. . . On the record before us, there is no genuine dispute that the
City lacked a strong basis in evidence to believe it would face
disparate-impact liability if it certified the examination results.
In other words, there 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.

6. . . . Many of the candidates had studied for months, at
considerable personal and financial expense, and thus the injury
caused by the City’s reliance on raw racial statistics at the end
of the process was all the more severe. Confronted with
arguments both for and against certifying the test results—and
threats of a lawsuit either way—the City was required to make a
difficult inquiry. But its hearings produced no strong evidence
of a disparate-impact violation, and the City was not entitled to
disregard the tests based solely on the racial disparity in the
results.
In a 1-2 page paper address the following:
· What type of human service agency is this research instrument
designed to study?
· How specifically will you apply this research instrument to
study your agency?
· Why is this research instrument the best research instrument
for your study as opposed to another assessment tool?
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APA format
The IRAC Method of Case Study Analysis
A Legal Model for the Social Studies
Not only did the legal profession give educators the
instructional technique of case studies, but it also contributed a
concomitant method of case study analysis. Although
disciplines such as business management, social sciences, and
medicine have extensively used the methodology of case
studies, students in these disciplines were not provided with a
method to analyze a case. Some of these cases required only an
individual value conclusion; other cases required a specific
conclusion based upon substantive knowledge of the discipline.
Still others required both types of conclusions. Only in law
classes are students given an unequivocal method for case

7. analysis. According to this method, students recognize a legal
issue from the facts in the case and then analyze the facts
according to a legal precedent and reach a conclusion.
The underlying assumptions of teaching-effectiveness research
can be applied to this topic in a social studies class: Teachers
cannot assume that all students on their own will develop a
method of case analysis; that initial success will motivate the
student to continue the analysis process; and that the students
require a clear demonstration or modeling of the case analysis
method (Brophy and Good 1986). The social studies literature
does not give examples of these analysis methods. Because the
use of case studies in the social studies fosters critical thinking,
class interaction, and personal initiative, a method of case study
analysis warrants the attention of social studies teachers.
When the case study instructional technique is used in the social
studies classroom, students are often required to comprehend,
assess, and evaluate amounts of information that may be
overwhelming. Unfortunately, students do not receive enough
practice in the method of case study analysis before they are
required to comprehend relationships, generalizations, and
patterns. Such a situation is self-defeating for students because
without acquiring the rudimentary skills of case analysis, they
will not be able to contribute to the lesson at hand.
In addition, students are then expected to make value judgments
about the facts, issues, and conclusions of a case study. To
make an informed and coherent value judgment, students must
first comprehend the facts, recognize the issues that arise from
those facts, analyze the facts in relation to the definition or rule
of a term, and then reach a conclusion about the analysis. To
make a value-laden decision such as "I don't agree with that,"
the student should first say that the facts produce issue X and
then analyze the facts in accordance with each element of the
rule in order to make a viable conclusion about whether the
issue is proved or disproved. With this procedure, the value
decision becomes meaningful to the individual student and to
the group participating in the case study discussion. This

8. process of analysis is known as the IRAC method.
The IRAC Method The IRAC method is an instructional tool
that can aid students in the comprehension and evaluation of
information so that they can make informed value decisions. It
is an acronym for Issue, Rule, Analysis, and Conclusion.
Although this is a legal model used to evaluate hypothetical
situations in law cases, it is by no means limited to the study of
the law. Useful for case studies presented in varied mediums
such as narratives, videos/films, or recordings, the IRAC
method may be applied to other activities such as defining a
term or demonstrating a concept, principle, relationship,
analogy, or contrasting idea. Often the instructional focus is on
the end result of case study discussion rather than on how to
"walk through" a method or approach to be used by the students
in the case analysis.
By using the IRAC method, social studies teachers can help
their students acquire a process for analyzing a case study. This
building block method, which starts with smaller chunks of
material, develops understanding relationships. It enhances the
immediate application of learning by translating theory into
practice to help students enlarge their vocabulary and attain new
concepts. The method demonstrates to students that the correct
analysis of a case gives them an evaluation and verification tool
to assist them in making meaningful value judgments.
Acquisition of a Process to Analyze Case Studies
A case study is a realistic application or demonstration of a
theory or principle. The student is required to relate textbook
material to a concrete situation and then make a practical
judgment. Students can relate to case studies because they
understand that they could possibly find themselves in similar
situations.
After reading, viewing, or hearing a case, students use the IRAC
method to recognize the facts that raise the issues. They then
apply the elements of the rule or definition to the facts to verify
or disprove the issues in the conclusion.
Students' analytical skills are developed through a systematic

9. mastery of complex problem solving in a rational manner.
Students become more aware of their own abilities and
limitations and are given the opportunity to practice in a
positive environment.
Another variation of this method includes informing students
about the entire case-i.e., issues, rules, analysis, and
conclusions-and then soliciting their input. In another method,
the teacher presents two cases with all of the aforementioned
elements and does not tell the students which is the correct one.
The teacher then has them choose. The danger in using either of
these methods is that the student is slighted. The teacher has
done too much work for the students, who are not required to
discover the issue, review the rule, and analyze the facts to
determine the correct conclusion (Lee 19X3).
An Example of the IRAC Method
Case: John told Sara that his sports car would travel 150 mph on
the freeway. John was anxious to impress Sara, so he crossed
the double yellow lines to pass the car in front of him. A car
was coming from the opposite direction and was forced off the
road; the other driver sustained head injuries when his car
overturned.
Issue: Has negligence been demonstrated?
Rule: Negligence requires that a duty was owed, that the duty
was breached, and that the breach was the actual and proximate
cause of damage.
Analysis: As a driver on the public freeway, John owed a duty
of due care not to pass a car when double yellow lines divide
the road. John had a duty not to expose this foreseeable plaintiff
to an unreasonable risk of harm. John failed to act as a
reasonable person in the same or similar circumstances when he
passed a car. John breached his duty of care when he violated a
statute not to cross the double yellow lines. John is the actual
cause of the other driver's injury; but for John, the accident
would not have occurred. It was foreseeable that another car
would be coming from the opposite direction. John is the
proximate cause of the driver's personal and property damage

10. because there is a connection between John's action and the
result.
Conclusion: John is liable for negligence because he violated a
statute.
Instead of plunging into the case analysis, the student takes the
elements of negligence, applies them to the facts, and builds a
relationship so that a conclusion can be reached. The five
elements are essential if negligence is to be proved. The student
is responsible for verifying each element in the facts that
corresponds with the rule. The conclusion will be correct if this
method is used.
Translating Theory into Practice
Social studies teachers may assume that students can analyze a
case without having had some prior sequential instruction. An
IRAC model can be used for vocabulary building and concept
attainment, even before students are introduced to a full-blown
case. In the following examples, the IRAC method either proves
or disproves the issues raised in a government class, a world
history class, and an American history class.
Example for a Government Class
Case: Sixty of the 100 senators present voted to cut off the
debate on an environmental issue. A petition with sixteen votes
had been circulated in the Senate. Senator Brown then spoke for
only an hour on this issue the first day after the petition was
signed.
Issue: Has cloture been demonstrated?
Rule: The Senate cuts off debate if three-fifths of the senators
present vote to do so two days after sixteen senators sign a
petition for it; each member may then speak for only one hour.
Analysis: The sixty represent three-fifths of the hundred
senators. Senator Brown spoke on the first day after the petition
was signed, making it the second day after sixteen senators
signed it. Senator Brown spoke for only one hour.
Conclusion: Therefore, cloture was demonstrated.
Example for a World History Class
Case: Elena and her family had moved from El Salvador to the

11. United States. During a current events discussion about natural
disasters such as the San Francisco earthquake and Hurricane
Hugo, Elena said she heard that certain buildings had been
expropriated by the U.S. government during these disasters.
Elena also said that her grandfather's farm had been taken by
the revolutionary soldiers and that the farm was now owned by
one of the soldiers and his family. Elena stated that in the
United States, some of the post offices and fire stations had
been used by the federal government to provide homes for the
disaster victims. She wondered if this arrangement by the U.S.
government were comparable to that experienced by her
grandfather in El Salvador.
Issues: Was the grandfather's farm expropriated by the
government of El Salvador? Were the post offices and fire
stations expropriated by the U.S. government? Rule:
Expropriate means that the federal government takes private
land or possessions from the owner for public use.
Analysis: The grandfather's farm qualifies as land, and we can
assume that he owned it or that it was in his rightful possession
until he had finished making payments on it. Consequently, it
was his private land. If it had been public land, it would have
been everyone's land, not just the grandfather's land. We do not
know if the grandfather and his family took their personal
possessions; the farm supplies, animals, crops, and other farm
buildings can be considered possessions and therefore part of
the farm. These possessions probably remained on the farm. It
appears that both the land and possessions were taken, although
either could be taken for expropriation to occur. Elena stated,
however, that the farm was taken by a soldier, not the
government of El Salvador. That statement would indicate that a
private soldier took the farm for his personal use and that the
farm was not taken by the federal government for public use.
The post offices and fire stations are public buildings paid for
by taxing private citizens. Their use is for everyone; therefore,
they are public buildings on public land and are possessions of
the public. During the disasters, the U.S. government did not

12. take private land for public use. The U.S. took public land for
public emergency use. The buildings were used for their normal
purposes after the disaster period.
Conclusion: The farm was not expropriated. The post offices
and fire stations were not expropriated.
Example for an American History Class
Case: Responding to the suggestion of his uncle, Phil, an
assembler at a ship-building plant in Alabama, decided to move
to Michigan to work at a new car plant. Phil moved in with his
uncle and applied for a job at the plant. Because the plant was
just beginning production, not all workers were hired for a
forty-hour week. Phil was told that he could work twenty hours
per week until he was hired full time. Phil started working but
was told that he could not receive group medical insurance
coverage until he was hired on a full-time basis. The group plan
applied only to union members for whom the car plant paid 100
percent of the premiums. Phil could not join the union until he
worked forty hours per week. Phil's uncle became very angry
when he heard about this and urged Phil to take the auto
workers union to court because the union was operating a closed
shop. Phil was not sure about this. He had read his contract that
stated that the union could enforce union shop contracts.
Issues: Did the auto workers union operate a closed shop? Was
the auto workers union allowed to enforce union shop contracts?
Rule: The 1947 Taft-Hartley Act outlawed closed shops that
required new workers to join a union before they could be
employed. This same act allowed a union shop contract that
forced new workers to join the union after they accepted
employment.
Analysis: The facts state that Phil was hired by the auto firm to
work twenty hours per week until he was hired later for a forty-
hour week. Phil had nothing in writing to guarantee that he
would be hired later for a forty-hour week. Phil did not have to
join the auto workers union as a condition for employment. He
could not, however, receive medical benefits or join the union
until he was scheduled to work forty hours per week. Phil's

13. uncle reached his conclusions before he knew all the facts.
Therefore, the auto plant was not a closed shop because the
union allowed Phil to be employed, even though he was not a
union member (see Garraty and McGaughey 1989).
Phil could have secured medical insurance at his own expense.
The auto firm, of course, paid for the cost of the insurance for
its full-time employees. It would certainly be to Phil's benefit to
have the company pay for the policy rather than his paying the
higher cost for individual insurance. Although the union did not
physically force the auto firm workers to join the union, it did,
by indirect means, require the auto workers to join the union in
order to receive medical coverage. In other words, the auto
workers union was allowed to enforce union shop contracts.
Conclusion: The auto workers union did not operate a closed
shop in defiance of the Taft-Hartley Act. The auto workers did
enforce a union shop contract as allowed by the Taft-Hartley
Act because Phil would not receive medical coverage if he did
not join the union.
Students can use these exercises as self-checking devices to
acquaint themselves with what is required to reach a coherent
conclusion in a case study. This beneficial technique increases
students' "vocabulary of experience," which reduces anxiety
about the unanticipated (Gullette 1982). In this manner,
students start with simple concept comprehension and build
toward more complex relationships.
Stevens (1982) asserts that the case method is inappropriate if a
spectrum of cases cannot be presented to show generalizations.
Students, however, must first become familiar with the rule or
definition before making an informed analysis to reach
conclusions to be applied to future relationships.
A Tool for Making Value Judgments
Numerous case studies require students to share their personal
values and opinions about an issue. Frequently, this is the most
important overall objective of a case study. Little importance is
given to the "how to" process of the student's arriving at a
conclusionary value statement. Often students pass over the

14. IRAC steps and just make personal value-opinion judgments.
Some value-laden questions for case study analysis include: Do
you agree with what X did; what would you have done; what are
some alternative solutions; and how urgent is each issue? Van
Gundy (1981) refers to the deviation between "what is" and
"what should be" when students are required only to make value
judgments in case analysis. The interpretations may differ from
person to person, and incorrect information may render case
analysis worthless.
Summary
Case studies can be used in many disciplines, and social studies
teachers can aid their students in developing a systematic
method to approach case studies. Often students are called upon
to give information about a topic and then subsequently state
their opinions about how the topics affect them, which is a
value statement. Much of the focus of attention in the classroom
is upon active student participation rather than upon acquainting
the students with a hands-on method for analyzing a case
through a step-by-step process. Once students acquire this skill
they can transfer it to case study analysis in other classes.
The IRAC method gives the students a frame of reference when
dealing with a particular issue. It could be considered a formula
because students are required to learn first the definition (rule)
of a term, to read the facts of the case to determine if the facts
raise the issue, to compare the facts with each element of the
rule to establish if the issue is existent or nonexistent, and to
give the conclusion.
By using the IRAC method, students will have a working tool
that can be used for practicing case study analysis on a smaller
scale. In this manner, students move in a linear fashion from
simple to more complex. By working through the method,
students can immediately see the application of the concept they
just learned to the facts of the case study. The students can
check themselves to determine if they understand the meaning
of a term and how it is practically applied before they are
required to assert a value judgment, which could be given on

15. the basis of a misunderstanding of the term and the issue arising
from the facts. The IRAC method both creates confidence in
students and positively reinforces the acquisition of accurate
information.
REFERENCES
Brophy, J., and T. Good. 1986. Teacher behavior and student
achievement. In Handbook of research on teaching 3rd ea.,
edited by M. Wittrock. New York: Macmillan.
Garraty, J., and R McGaughey. 1989. A short history of the
American nation. New York: Harper and Row.
Gullette, M. 1982. The art and craft of teaching. Boston:
Harvard University Press.
Lee, U. S. 1983. Public management and case study methods.
Teaching Political Science (Fall)2:6-14.
Stevens, B. 1982. Educating the nurse manager. Maryland: Lord
Publishing.
Van Gundy, A. 1981. Techniques of structured problem solving.
New York: Van Nostrand Reinhold.
~~~~~~~~
By MARIE BITTNER
MARIE BITTNER is a professor in the Department of Education
at California State University in Chico.
Reference:
Bittner, M. (1990). The IRAC method of case study analysis.
Social Studies, 81(5), 227