Title VII and Equal Employment Opportunity Commission (EEOC) guidelines on discrimination in employment are not always the basis for court decisions in individual cases where intent to discriminate is challenged. A number of employment discrimination cases over the last decade have invalidated employee selection practices of local school boards and licensing agencies following the guidelines. Applicability of Title VII and EEOC rules to state licensing agencies still has not been definitively resolved by the courts. The consistent invalidation of National Teachers Examination (NTE) as an exclusive employment selection by the courts over the course of the past five years is of great significance to those concerned with the general problem of teacher certification. In recent years, many states have amended their teacher certification regulations to permit or require a Competency Based Teacher Education (CBTE) orientation in their approved program credentialling practices. The educational community should expect direct or indirect judicial application of specific validation standards to teacher credentialling regulations and practices. Licensing and certification authorities will increasingly be directly subjected to validation standards. However, standards are likely to be applied more "flexibly" in court cases dealing with equal employment opportunity issues. Increasingly courts will be requiring adherence to the reform principles that advocates of CBTE have established. (JD)