Reeves v. Sanderson Plumbing Products

120 S.Ct. 2097 (U.S. June 12, 2000) ; Clearinghouse Number: 53054

Description

Supreme Court Clarifies Evidentiary Standard for Age Discrimination Cases

Abstract

The U.S. Supreme Court held that plaintiff’s prima facie case of discrimination (as defined in McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802 (1973)), combined with sufficient evidence for a reasonable fact finder to reject employer’s nondiscriminatory explanation for its decision, might permit the trier of fact to conclude that employer unlawfully discriminated. Respondent company discharged petitioner employee, 57, a supervisor for company, after an investigation allegedly revealed numerous time-keeping errors and misrepresentations by employee and two others. In his suit, employee contended that in violation of the Age Discrimination in Employment Act of 1967 employer fired him because of his age. At trial, company argued that it fired employee for failure to maintain accurate attendance records; employee argued that company’s explanation was a pretext for age discrimination. A jury found that company’s age discrimination was willful, but the Fifth Circuit reversed; it held that employee had not introduced sufficient evidence to sustain the jury’s finding. The Supreme Court noted that employee established a prima facie case of discrimination and company met its burden to produce evidence of a legitimate, nondiscriminatory reason for the firing. Employee made a substantial showing that company’s explanation was false and cast doubt on his responsibility for any failure to discipline late and absent employees. The Supreme Court found that the Fifth Circuit—in ignoring the evidence supporting employee’s prima facie case and challenging company’s explanation for its decision—erroneously presumed that a plaintiff must always introduce additional, independent evidence of intentional discrimination. Because employee introduced sufficient evidence for the jury to find that company intentionally discriminated, company was not entitled to judgment as a matter of law.

Additional Information

Docket Date
2000-06-12 00:00:00+00:00

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