McDonnell Douglas Corporation v. Green: Clarifying Cases

2012-09-17 05:55:50 by admin

McDonnell Douglas Corporation v. Green

McDonnell Douglas Corporation v. Green: The Initial Decision

The Supreme Court clarified what happens once an employer’s justification is proved to be untrue. In St. Mary’s Honor Center v. Hicks (1993), the Court held that employees or job seekers do not automatically prove their cases of disparate treatment discrimination when they show that the reasons offered by employers for adverse employment actions are mere pretexts. In Hicks, the Court expressed its concern that large corporations might not be able to ascertain the exact reason why someone was not hired or promoted or was fired and that in this context an employer’s failure to provide the true reason for an employment decision should not automatically impose liability without additional facts. However, in a case in which the individual offering the reason is the same person who made the employment decision, evidence of pretext may be strong circumstantial evidence. There was some confusion in the lower courts that Hicks required additional independent evidence of employment discrimination.

In Reeves v. Sanderson Plumbing Products (2000), an age discrimination case, the Supreme Court clarified Hicks by explaining judges should weigh a number of factors to determine whether discrimination occurred, including the strength of the prima facie case and the fact that an employer’s reason for the adverse action was proven to be a mere pretext. Even though employees always bear the burden of proving discrimination, the Court explained in Reeves that it did not require additional independent evidence of discrimination.