<P> The 1991 Act expanded the remedies available to victims of discrimination by amending Title VII of the 1964 Act . </P> <P> Congress had amended Title VII once before, in 1972, when it broadened the coverage of the Act . It was moved to overhaul Title VII in 1991 and to harmonize it with Section 1981 jurisprudence, with a series of controversial Supreme Court decisions: </P> <Ul> <Li> Patterson v. McLean Credit Union, 491 U.S. 164 (1988), which held that an employee could not sue for damages caused by racial harassment on the job because even if the employer's conduct were discriminatory, the employer had not denied the employee the "same right...to make and enforce contracts...as is enjoyed by white citizens," the language that Congress chose in passing the law in 1866 . </Li> <Li> Wards Cove Packing Co. v. Atonio, 490 U.S. 642 (1989), which made it more difficult for employees of Wards Cove Packing Company to prove that an employer's personnel practices, neutral on their face, had an unlawful disparate impact on them by requiring that they identify the particular policy or requirement that allegedly produced inequalities in the workplace and show that it, in isolation, had that effect . </Li> <Li> Price Waterhouse v. Hopkins, 490 U.S. 228 (1989), which held that the burden of proof shifted, once an employee had proved that an unlawful consideration had played a part in the employer's personnel decision, to the employer to prove that it would have made the same decision if it had not been motivated by that unlawful factor, but such proof by the employer would constitute a complete defense for the employer . </Li> <Li> Martin v. Wilks, 490 U.S. 755 (1989), which permitted white firefighters who had not been party to the litigation, establishing a consent decree governing hiring and promotion of black firefighters in the Birmingham, Alabama, Fire Department, to bring suit to challenge the decree . </Li> </Ul> <Li> Patterson v. McLean Credit Union, 491 U.S. 164 (1988), which held that an employee could not sue for damages caused by racial harassment on the job because even if the employer's conduct were discriminatory, the employer had not denied the employee the "same right...to make and enforce contracts...as is enjoyed by white citizens," the language that Congress chose in passing the law in 1866 . </Li>

Which of the following is an issue addressed by the civil rights act of 1991