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Keywords

plaintiffliabilityappealburden of proofdiscriminationpartnershipcivil rights

plaintiffdefendantliabilitypartnershiprespondent

Related Cases

Price Waterhouse v. Hopkins, 490 U.S. 228, 109 S.Ct. 1775, 104 L.Ed.2d 268, 49 Fair Empl.Prac.Cas. (BNA) 954, 49 Empl. Prac. Dec. P 38,936, 57 USLW 4469

Facts

Ann Hopkins, a senior manager at Price Waterhouse, was proposed for partnership in 1982 but her candidacy was held for reconsideration. When the partners later refused to repropose her, she sued the firm under Title VII, claiming sex discrimination. The District Court found in her favor, ruling that the firm had discriminated against her based on sex due to sex stereotyping in the evaluation process. The Court of Appeals affirmed the ruling, but both courts required the firm to prove its case by clear and convincing evidence.

Respondent was a senior manager in an office of petitioner professional accounting partnership when she was proposed for partnership in 1982. She was neither offered nor denied partnership but instead her candidacy was held for reconsideration the following year.

Issue

Did Price Waterhouse violate Title VII by discriminating against Ann Hopkins based on her sex during the partnership evaluation process?

Rule

Under Title VII of the Civil Rights Act of 1964, an employer cannot make employment decisions based on gender. If a plaintiff shows that gender was a motivating factor in an employment decision, the employer can avoid liability by proving that it would have made the same decision regardless of the gender consideration. The burden of proof lies with the employer to demonstrate that the decision would have been the same absent the discriminatory motive.

When a plaintiff in a Title VII case proves that her gender played a part in an employment decision, the defendant may avoid a finding of liability by proving by a preponderance of the evidence that it would have made the same decision even if it had not taken the plaintiff's gender into account.

Analysis

The court analyzed whether the comments made by partners about Hopkins reflected sex stereotyping and whether these comments influenced the decision to hold her candidacy. The evidence indicated that some partners made remarks that suggested a bias against her because she was a woman. The court concluded that the firm failed to prove that it would have made the same decision without considering her gender, thus establishing liability under Title VII.

The District Court's finding that sex stereotyping was permitted to play a part in evaluating respondent as a candidate for partnership was not clearly erroneous. This finding is not undermined by the fact that many of the suspect comments made about respondent were made by partners who were supporters rather than detractors.

Conclusion

The Supreme Court reversed the lower courts' requirement for the employer to prove its case by clear and convincing evidence and remanded the case for further proceedings consistent with its opinion.

The judgment is reversed, and the case is remanded.

Who won?

Ann Hopkins prevailed in her sex discrimination claim against Price Waterhouse. The court found that the firm had unlawfully discriminated against her based on sex, as evidenced by the comments made by partners that reflected sex stereotyping. The court ruled that the firm did not meet its burden of proof to show that it would have made the same decision regarding her candidacy without the influence of gender bias.

The District Court ruled in respondent's favor on the question of liability, holding that petitioner had unlawfully discriminated against her on the basis of sex by consciously giving credence and effect to partners' comments about her that resulted from sex stereotyping.

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