- In Reeves v Sanderson Plumbing Products, Inc (June 12, 2000), the U.S. Supreme Court, in a unanimous opinion, clarified the kind and amount of evidence necessary to sustain a jury's verdict in an employment discrimination case.
- In most employment cases, direct evidence of discrimination is lacking. Consequently, most employees attempt to prove discrimination through circumstantial evidence using the burden shifting method established by the U.S. Supreme Court in McDonnell Douglas Corp v Green. Under McDonnell Douglas, an employee has the initial burden of proving a prima facie case of discrimination. Typically, employees must show that they were a member of a protected class, were qualified for their position, suffered an adverse employment action, and were replaced by someone outside of the protected class. The burden then shifts to the employer to articulate a legitimate, non-discriminatory reason for the adverse employment action. Once the employer produces its explanation, the employee must prove that the employer's reason was not its true reason, but was a pretext for discrimination.
- In Reeves, the employee used the above burden shifting method to try to prove that he was discharged because of his age. The employee established a prima facie case: he was over forty, he was qualified for his supervisor position, he was discharged, and he was replaced by a younger person. He also produced evidence that the reason given for his discharge, the keeping of inaccurate attendance records, was false. He offered evidence that he properly maintained the attendance records. He also produced evidence that he was not responsible for any failure to discipline late and absent employees, but, rather, another employee had that responsibility.
- The jury ruled in the employee's favor, but the court of appeals reversed the verdict and ruled in favor of the employer. The court conceded that a reasonable jury could have concluded that the employer's explanation for the termination was false. The court, however, reasoned that in addition, the jury had to find that the employee presented sufficient evidence that he was discharged because of his age. The court examined the employee's evidence that the decision maker made age-related comments and singled him out for harsher treatment but found that the alleged comments were not made in the context of the employee's termination, there was no allegation that the other two individuals involved in the decision to discharge the employee were motivated by age, and that these two individuals were over the age of 50. The court concluded that the employee had not presented sufficient evidence for a jury to conclude that he had been discharged because of his age.
- The supreme court reversed the court of appeals. According to the court, in appropriate circumstances, the jury can "reasonably infer from the falsity of the explanation that the employer is dissembling to cover up a discriminatory purpose." The supreme court, therefore, decided that an employee's prima facie case, combined with sufficient evidence to find that the employer's asserted justification is false, may permit the jury to conclude that the employer unlawfully discriminated. The court cautioned, however, that such a showing by the employee will not always be adequate to sustain a jury's finding of liability. For example, an employer would be entitled to win if the record demonstrated some other, nondiscriminatory reason for the employer's decision.
- The U.S. Supreme Court's decision reemphasizes the importance to employers of providing employees with a truthful explanation for their disciplinary decisions. To spare an employee's feelings or to avoid a confrontation, employers sometimes fail to provide employees with the real reason for the employer's action. For example, an employer will tell an employee he is being laid off for economic reasons when, in fact, he is being discharged because of performance problems. Under such a scenario, a jury may be permitted to infer that the employer unlawfully discriminated.
U.S. Supreme Court Clarifies Evidence Needed To Sustain Jury Verdicts in Employment Discrimination Cases
This article was edited and reviewed by FindLaw Attorney Writers | Last reviewed March 26, 2008
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