THE JUDGE HELD THAT THE DETROIT POLICE DEPARTMENT'S POLICY SINCE 1974 OF PROMOTING ONE BLACK OFFICER TO SERGEANT FOR EVERY WHITE OFFICER PROMOTED UNLAWFULLY DISCRIMINATES AGAINST WHITE OFFICERS, PRIMARILY BECAUSE THERE WAS NO PROOF OF PAST DISCRIMINATION IN THE DEPARTMENT AND BECAUSE EMPLOYERS MAY NOT VOLUNTARILY ADOPT A QUOTA TYPE OF RELIEF. OTHER FACTORS INFLUENCING THE JUDGE'S DECISION WERE THAT OPERATIONAL NEEDS OF THE DEPARTMENT DID NOT JUSTIFY THE AFFIRMATIVE ACTION PLAN, SINCE THERE WAS NO EVIDENCE THAT THE INCREASED NUMBER OF MINORITIES IN SUPERVISORY RANKS HAD IMPROVED THE OVERALL EFFECTIVENESS OF THE DEPARTMENT, AND THAT THE APPROPRIATE GEOGRAPHICAL AREA FOR DEFINING THE LABOR FORCE FROM WHICH POLICE OFFICERS ARE DRAWN IS THE 1970 CENSUS DEFINITION OF THE DETROIT STANDARD METROPOLITAN STATISTICAL AREA. THE COMMENTARY ASSUMES THAT THERE ARE UNIQUE CONCERNS IN LAW ENFORCEMENT THAT MAY JUSTIFY DIFFERENT LAWS GOVERNING EMPLOYMENT PRACTICES. GIVEN THE CLOSE CONNECTIONS AMONG RACE, CULTURE, VALUES, AND POLICE BEHAVIOR, EQUITABLE EMPLOYMENT PRACTICES SHOULD NOT BE THE ONLY CONCERN IN LITIGATION INVOLVING MINORITY QUOTAS. POLICE EFFECTIVENESS SHOULD BE GIVEN EQUAL CONSIDERATION. POLICE EFFECTIVENESS IS DETERMINED FOR THE AREA IN RELATION TO THE NUMBER OF BLACKS, OTHER MINORITIES, AND WHITES IN LAW ENFORCEMENT, AND THE GEOGRAPHY OF PERSONNEL RECRUITMENT ALSO IS EXAMINED. CASE LAW IS CITED.