Category:
Into These Courts
Difficulty Level:
Extreme

In Recognition of the Importance of Title Vll in the Development of Civil Rights Law and Policy.

A 1973 landmark United States Supreme Court case was an early ruling regarding the burden and nature of proof in proving a Title VII case and the order in which plaintiffs and defendants present proof. Since its issuance in 1973, all federal courts have subsequently adopted the order and allocation of proof set out in this case  for all claims of disparate-treatment employment discrimination that are not based on direct evidence of discriminatory intent.  Name the Supreme Court Case.
 

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Historical Notes

At the time of the lawsuit, McDonnell Douglas was a large aerospace company based in St. Louis, Missouri; it has since merged with The Boeing Company. The case was brought by Percy Green, an African American mechanic and laboratory technician laid off by McDonnell Douglas in 1964 during a reduction in force, who was also a long-time civil rights activist.

Green protested his discharge, saying it was racially motivated. He and others used cars to block roads to McDonnell Douglas factories. On one occasion, someone used a chain to lock the front door of a McDonnell Douglas downtown business office, preventing employees from leaving; it was not certain that Green was responsible for this action.  Not long after the locked-door incident, McDonnell Douglas advertised for vacant mechanic positions. Although Green was qualified for the advertised positions, he was not hired.  McDonnell Douglas cited his participation in blocking traffic and chaining the building.  Green was rejected for re-employment on the grounds of the illegal conduct.

Green filed a complaint with the Equal Employment Opportunity Commission (EEOC) charging violation of Title VII of the Civil Rights Act of 1964. Subsequently; he sued in U.S. District Court, and later appealed the decision to the U.S. Court of Appeals for the Eighth Circuit before the Supreme Court agreed to hear the case.
The EEOC found that there was reasonable cause to believe that petitioner's rejection of respondent violated 704 (a) of the Act, which forbids discrimination against applicants or employees for attempting to protest or correct allegedly discriminatory employment conditions, but made no finding on respondent's allegation that petitioner had also violated 703 (a) (1), which prohibits discrimination in any employment decision.

Following unsuccessful EEOC conciliation efforts, respondent brought suit in the District Court, which ruled that respondent's illegal activity was not protected by 704 (a) and dismissed the 703 (a) (1) claim because the EEOC had made no finding with respect to it..

The Court of Appeals affirmed the 704 (a) ruling, but reversed with respect to 703 (a) (1), holding that an EEOC determination of reasonable cause was not a jurisdictional prerequisite to claiming a violation of that provision in federal court.

The McDonnell Douglas case established the order and framework that employment discrimination cases must follow:

  1. The plaintiff (employee) must first establish a prima facie case of discrimination which he can satisfy by showing that he belongs to a racial minority; he applied and was qualified for a job the employer was trying to fill; though qualified, he was rejected; and thereafter the employer continued to seek applicants with complainant's qualifications.
  2. The defendant (employer) must produce evidence of a legitimate non-discriminatory reason for its actions. If this occurs, then the presumption of discrimination dissipates.
  3. The plaintiff must then present facts to show an inference of discrimination. The plaintiff may do so either by showing that the defendant's explanation is insufficient and only a pretext for discrimination, or by otherwise proving that the defendant's actions used one of the listed unlawful discriminatory parameters.

The significance of this case is that it allows the plaintiff (employee) to shift the questions to be proved from whether the defendant has acted "because of" an unlawful discriminatory factor to whether the defendant has lied about the reasons it took action.

In McDonnell Douglas Corporation v. Green (411 U.S. 792 (1973),  by a 9-0 vote, the United States Supreme Court held that a charging party can prove unlawful discrimination indirectly by showing, for example, in a hiring case that: (1) the charging party is a member of a Title VII protected group; (2) he or she applied and was qualified for the position sought; (3) the job was not offered to him or her; and (4) the employer continued to seek applicants with similar qualifications. If the plaintiff can prove these four elements, the employer must show a legitimate lawful reason why the individual was not hired. The employee still may prevail if he or she discredits the employer's asserted reason for not hiring him or her.

The case was decided by the United States Supreme Court on May 14, 1973.