Law School Case Brief
St. Mary's Honor Ctr. v. Hicks - 509 U.S. 502, 113 S. Ct. 2742 (1993)
Under the McDonnell Douglas scheme, establishment of the prima facie case of race discrimination in employment in effect creates a presumption the employer unlawfully discriminated against the employee. The McDonnell Douglas presumption places upon the defendant the burden of producing an explanation to rebut the prima facie case -- i.e., the burden of "producing evidence" that the adverse employment actions were taken for a legitimate, nondiscriminatory reason. If the defendant carries this burden of production, the presumption raised by the prima facie case is rebutted, and drops from the case. The plaintiff then has the full and fair opportunity to demonstrate, through presentation of his own case and cross-examination of the defendant's witnesses, that the proffered reason was not the true reason for the employment decision, and that race was. He retains that ultimate burden of persuading the trier of fact that he has been the victim of intentional discrimination.
A black employee of a halfway house operated by the Missouri department of corrections and human resources brought an action under the Civil Rights Act alleging that the halfway house had violated 703(a)(1) by demoting and then discharging the employee because of his race. The District Court, acting as trier of fact in a full bench trial, found that the employee had established a prima facie case of racial discrimination, and the reasons that the employer gave for the demotion and discharge were not the real reasons for the demotion and discharge. Unfortunately, the Court ruled for the employer on the basis that the employee had failed to carry his ultimate burden of proving that his race was the determining factor in the employer's allegedly discriminatory actions. On appeal, the United States Court of Appeals for the Eighth Circuit reversed and remanded, holding that once the employee had proved all of the employer's proffered reasons for the adverse employment actions to be pretextual, the employee was entitled to judgment as a matter of law.
Was the employee entitled to judgment as a matter of law?
The Court reversed and remanded the appellate court's judgment that the employee was entitled to judgment as a matter of law once petitioners' proffered reasons for the employment action against the employee were discredited since he had established a prima facie case under the McDonnell Douglas scheme. The appellate court failed to recognize that the presumption of intentional racial discrimination created by establishing a prima facie case fell away when petitioners met their burden of producing evidence showing non-discriminatory reasons for their action. The employee at all times bore the ultimate burden of persuasion and had to prove that petitioners intentionally discriminated against him because of his race.
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