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Keywords

appealburden of proofdiscriminationcivil rightsrespondent
appealtrialburden of proofdiscriminationcivil rightsrespondent

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McDonnell Douglas Corp. v. Green, 411 U.S. 792, 93 S.Ct. 1817, 36 L.Ed.2d 668, 5 Fair Empl.Prac.Cas. (BNA) 965, 5 Empl. Prac. Dec. P 8607

Facts

The respondent, a black civil rights activist, was laid off from his job at McDonnell Douglas Corp. and subsequently engaged in protests against the company, which included illegal activities. After the company advertised for mechanics, the respondent applied for re-employment but was rejected due to his prior illegal conduct during protests. He filed a complaint with the EEOC, which found reasonable cause for discrimination under section 704(a) but made no finding regarding section 703(a)(1). The District Court dismissed the section 703(a)(1) claim, leading to an appeal.

Issue

Whether a complainant's right to sue under the Civil Rights Act of 1964 is restricted to charges for which the EEOC has made findings of reasonable cause, and whether the complainant established a prima facie case of racial discrimination.

Whether a complainant's right to bring suit under the Civil Rights Act of 1964 is restricted to charges for which the EEOC has made findings of reasonable cause, and whether the complainant established a prima facie case of racial discrimination.

Rule

A complainant's right to bring suit under the Civil Rights Act of 1964 is not confined to charges for which the EEOC has made a reasonable-cause finding. In a private complaint under Title VII, the complainant must establish a prima facie case of racial discrimination.

A complainant's right to bring suit under the Civil Rights Act of 1964 is not confined to charges as to which the EEOC has made a reasonable-cause finding, and the District Court's error in holding to the contrary was not harmless since the issues raised with respect to s 703(a)(1) were not identical to those with respect to s 704(a) and the dismissal of the former charge may have prejudiced respondent's efforts at trial.

Analysis

The Supreme Court found that the District Court erred in dismissing the section 703(a)(1) claim based on the lack of an EEOC finding. The Court agreed with the Court of Appeals that the respondent had established a prima facie case of racial discrimination by showing he belonged to a racial minority, was qualified for the job, was rejected, and that the employer continued to seek applicants with his qualifications. The employer's stated reason for rejection was based on the respondent's illegal conduct, which the Court deemed sufficient to meet the employer's burden of proof at that stage.

Here, the Court of Appeals, though correctly holding that respondent proved a prima facie case, erred in holding that petitioner had not discharged its burden of proof in rebuttal by showing that its stated reason for the rehiring refusal was based on respondent's illegal activity. But on remand respondent must be afforded a fair opportunity of proving that petitioner's stated reason was just a pretext for a racially discriminatory decision, such as by showing that whites engaging in similar illegal activity were retained or hired by petitioner.

Conclusion

The Supreme Court remanded the case for further proceedings, allowing the respondent a fair opportunity to prove that the employer's stated reason for rejection was a pretext for racial discrimination.

The cause is hereby remanded to the District Court for reconsideration in accordance with this opinion.

Who won?

The respondent prevailed in the Supreme Court, as the Court ruled that he had the right to pursue his claim under section 703(a)(1) despite the lack of an EEOC finding.

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