Law School Case Brief
Tex. Dep't of Cmty. Affairs v. Burdine - 450 U.S. 248, 101 S. Ct. 1089 (1981)
There are basic allocation of burdens and order of presentation of proof in a Title VII of the Civil Rights Act of 1964, 42 U.S.C.S. § 2000e et seq., case alleging discriminatory treatment. First, the plaintiff has the burden of proving by the preponderance of the evidence a prima facie case of discrimination. Second, if the plaintiff succeeds in proving the prima facie case, the burden shifts to the defendant to articulate some legitimate, nondiscriminatory reason for the employee's rejection. Third, should the defendant carry this burden, the plaintiff must then have an opportunity to prove by a preponderance of the evidence that the legitimate reasons offered by the defendant were not its true reasons, but were a pretext for discrimination.
Respondent female employee of petitioner Texas Department of Community Affairs brought an action against the Department in the United States District Court for the Western District of Texas, alleging that the Department's failure to promote her and its subsequent decision to terminate her employment had been predicated on gender discrimination in violation of Title VII of the Civil Rights Act of 1964 (42 USCS 2000e et seq.). After a bench trial, the District Court held that neither decision was based on gender discrimination, the court relying on testimony that the decisions were based on consultation among trusted advisors and on a nondiscriminatory evaluation of the relative qualifications of the individuals involved and that the Department thought that it could improve efficiency by terminating the employee and two others who did not work well together. On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the District Court's decision that the employee was not discriminated against when she was not promoted, but reversed the District Court's finding that the Department's testimony sufficiently had rebutted the employee's prima facie case of gender discrimination in the decision to terminate her employment, the court reaffirming its previously announced views that the defendant in a Title VII case bears the burden of proving by a preponderance of the evidence the existence of legitimate, nondiscriminatory reasons for the employment action and that the defendant also must prove by objective evidence that those hired or promoted were better qualified than the plaintiff, and finding that the Department had not met either of these evidentiary burdens on the discharge issue. Petitioner Department sought review.
In a terminated employee's employment discrimination case brought under Title VII of the Civil Rights Act of 1964, did the appellate court err by requiring the employer to prove by a preponderance of the evidence the existence of nondiscriminatory reasons for terminating the employee?
On certiorari, the Supreme Court of the United States explained that the narrow question presented is whether, after the plaintiff has proved a prima facie case of discriminatory treatment, the burden shifts to the defendant to persuade the court by a preponderance of the evidence that legitimate, nondiscriminatory reasons for the challenged employment action existed. In reaching its decision, the Court considered the nature of the evidentiary burden placed upon the defendant in an employment discrimination suit brought under Title VII of the Civil Rights Act of 1964. The Court held that the Circuit Court erred by requiring the employer to prove by a preponderance of the evidence the existence of nondiscriminatory reasons for terminating the employee and that the person retained instead had superior objective qualifications for the position. The employer bore only the burden of explaining clearly the nondiscriminatory reasons for its actions when the employee has proved a prima facie case of discrimination. Accordingly, the Court vacated the Circuit Court's decision and remanded for application of the correct standard.
The Court discussed the burden-shifting framework of McDonnell Douglas, setting forth the basic allocation of burdens and order of presentation of proof in a Title VII case alleging discriminatory treatment.
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