This Note analyzes the holding in Patterson v. McLean Credit Union; provides a survey of the number and type of section 1981 claims in the Eighth Circuit since January 1, 1985; and finally examines how Patterson would have affected the three successful section 1981 claims in the Eighth Circuit.

I. Introduction

II. Facts of Patterson

III. Holding in Patterson

IV. Analysis of Patterson ... A. Section 1981 Extends to Private Contracts ... B. The Same Right to Make Contracts ... C. The Same Right to Enforce Contracts ... D. Promotion Claims ... E. The Relationship between Section 1981 and Title VII

V. Survey of Eighth Circuit Section 1981 Claims

VI. Successful Section 1981 Claims

VII. Conclusion