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Keywords

plaintiffdefendantappealtrialburden of proofdiscriminationcivil rights
plaintiffdefendantappealburden of proofdiscriminationcivil rightsrespondent

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McDonnell Douglas; U.S. v.

Facts

The employer hired the employee for the position of accounting clerk. The employee alleged that the employer's failure to promote and subsequent decision to terminate her had been predicated on gender discrimination in violation of Title VII of the Civil Rights Act of 1964. The appellate court reversed the trial court's finding that the employer had rebutted the prima facie case of gender discrimination. The Supreme Court held that the appellate court erred by requiring the employer to prove by a preponderance of the evidence the existence of nondiscriminatory reasons for terminating the employee.

Petitioner, the Texas Department of Community Affairs (TDCA), hired respondent, a female, in January 1972, for the position of accounting clerk in the Public Service Careers Division (PSC). Respondent filed this suit in the United States District Court for the Western District of Texas. She alleged that the failure to promote and the subsequent decision to terminate her had been predicated on gender discrimination in violation of Title VII.

Issue

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.

This case requires us to address again 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, 42 U. S. C. 2000e et seq . 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.

Rule

The employer's burden is satisfied if he simply 'explains what he has done' or '[produces] evidence of legitimate nondiscriminatory reasons.'

We stated in Sweeney that 'the employer's burden is satisfied if he simply 'explains what he has done' or '[produces] evidence of legitimate nondiscriminatory reasons.'

Analysis

The court found that the Court of Appeals had misconstrued the nature of the burden that McDonnell Douglas and its progeny place on the defendant. The court stated that the employer's burden is satisfied if he simply explains what he has done or produces evidence of legitimate nondiscriminatory reasons. The Court of Appeals required much more, placing on the defendant the burden of persuading the court that it had convincing, objective reasons for preferring the chosen applicant above the plaintiff.

The Court of Appeals has misconstrued the nature of the burden that McDonnell Douglas and its progeny place on the defendant. It is plain that the Court of Appeals required much more: it placed on the defendant the burden of persuading the court that it had convincing, objective reasons for preferring the chosen applicant above the plaintiff.

Conclusion

The judgment of the appellate court was vacated, and the case was remanded for further proceeding consistent with the Supreme Court's opinion.

The judgment of the appellate court was vacated, and the case was remanded for further proceeding consistent with the Supreme Court's opinion.

Who won?

The Texas Department of Community Affairs prevailed because the Supreme Court found that the appellate court had erred in its interpretation of the burden of proof required of the employer.

The Texas Department of Community Affairs prevailed because the Supreme Court found that the appellate court had erred in its interpretation of the burden of proof required of the employer.

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