Law School Case Brief
Christian v. Wal-Mart Stores, Inc. - 252 F.3d 862 (6th Cir. 2001)
The United States Court of Appeals for the Sixth Circuit concludes that the three-part prima facie test developed by the United States District Court for the District of Maryland is the most useful to courts evaluating claims of race discrimination in the commercial establishment context and therefore adopts it as its own. In a 42 U.S.C.S. § 1981 commercial establishment case, a plaintiff must prove: (1) plaintiff is a member of a protected class; (2) plaintiff sought to make or enforce a contract for services ordinarily provided by the defendant; and (3) plaintiff was denied the right to enter into or enjoy the benefits or privileges of the contractual relationship in that plaintiff was deprived of services while similarly situated persons outside the protected class were not and/or plaintiff received services in a markedly hostile manner and in a manner which a reasonable person would find objectively discriminatory.
Plaintiffs Lois Christian, who was African-American, and Amber Edens, who was white, went to a store owned an operated by defendant Wal-Mart Stores, Inc., on Dec. 15, 1997 to buy Christmas presents. A Wal-Mart employee offered Christian repeated assistance, which Christian declined. Edens was offered no assistance. The employee, claiming that Christian was shoplifting, reported the incident to a supervisor, who in turn called the police. Thereafter, Christian and Edens were escorted out of the store by police officers and were not allowed to complete their purchases. Christian and Edens filed a lawsuit against Wal-Mart in federal district court under 42 U.S.C.S. § 1981, 42 U.S.C.S. § 2000a, and Ohio Revised Code § 4112.02(G), alleging that they were refused their right to make a contract with Wal-Mart because of Christian's race. The trial court granted Wal-Mart judgment as a matter of law. The trial court determined that Christian failed to establish that Wal-Mart's employee had the requisite intent to discriminate when reporting an alleged shoplifting incident to her supervisor or that the supervisor's action in asking the plaintiffs to leave the store was motivated by racial animus. Plaintiffs challenged the judgment.
Was it proper for the trial court to grant Wal-Mart judgment as a matter of law?
The appellate court reversed the judgment and the case was remanded for a new trial. The court held that the trial court erred in omitting the traditional McDonnell Douglas burden shifting framework from its analysis. After establishing the appropriate prima facie test to evaluate race discrimination claims in the commercial establishment context, the appellate court found that Christian met the prima facie test because she was a protected class member, she had sought to make a contract with Wal-Mart, and the employee's apparent ignorance of her race did not shield Wal-Mart from liability since the employee's racial animus could have been imputed to the supervisor under the circumstances. Since a reasonable jury could have inferred the ultimate fact of discrimination from the falsity of the employee's explanation combined with evidence supporting the prima facie case, the trial court erred in granting Wal-Mart judgment as a matter of law.
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