3 id., at 82-83. Id., at 694. 2 id., Doc. 3 id., at 80. We recommend using If you do not cancel your Study Buddy subscription within the 14 day trial, your card will be charged for your subscription. Reeves filed this suit, contending that he had been terminated because of his age in violation of the Age Discrimination in Employment Act of 1967 (ADEA). CASE SYNOPSIS: Petitioner former employee filed a petition … Certainly there will be instances where, although the plaintiff has established a prima facie case and set forth sufficient evidence to reject the defendant's explanation, no rational factfinder could conclude that the action was discriminatory. Respondent then renewed its motion for judgment as a matter of law and alternatively moved for a new trial, while petitioner moved for front pay. Reeves v. Sanderson Plumbing Products, Inc., 530 U.S. 133 (2000), was a case before the United States Supreme Court concerning age discrimination in employment. Argued March 21, 2000. 530 U.S. 133. 100 F.3d 1061 - SHERIDAN v. E.I. The trial court granted judgment to Reeves and the appellate court reversed, claiming that Reeves did not present enough evidence to prove intentional discrimination. There we held that the factfinder's rejection of the employer's legitimate, nondiscriminatory reason for its action does not compel judgment for the plaintiff. In Reeves, the employer contended that the … In October 1995, petitioner Roger Reeves was 57 years old and had spent 40 years in the employ of respondent, Sanderson Plumbing Products, Inc. , a manufacturer of toilet seats and covers. As a result of that audit, petitioner was placed on 90 days' probation for unsatisfactory performance. Co., 997 F. 2d 1433, 1436 (CA11 1993); Boeing Co. v. Shipman, 411 F. 2d 365, 374 (CA5 1969) (en banc). 3 id., at 23, 70; 4 id., at 335-336. At trial, respondent contended that it had fired petitioner due to his failure to maintain accurate attendance records, while petitioner attempted to demonstrate that respondent's explanation was pretext for age discrimination. Cf. Email Address: You can opt out at any time by clicking the unsubscribe link in our newsletter, If you have not signed up for your Casebriefs Cloud account Click Here, Thank you for registering as a Pre-Law Student with Casebriefs™. Whether the defendant was in fact motivated by discrimination is of course for the finder of fact to decide; that is the lesson of St. Mary's Honor Center v. Hicks, 509 U. S. 502 (1993). Reeves' duties included making sure workers under his supervision were … AFFIRMING AMBIGUITY: REEVES V SANDERSON PLUMBING PROD UCTS, INC. AND THE BURDEN-SHIFTING FRAMEWORK OF DISPARATE TREATMENT CASES I. Hazen Paper Co. v. Biggins, 507 U. S. 604, 610 (1993). See id., at 517 ("[P]roving the employer's reason false becomes part of (and often considerably assists) the greater enterprise of proving that the real reason was intentional discrimination"). The court explained, however, that this was "not dispositive" of the ultimate issue--namely, "whether Reeves presented sufficient evidence that his age motivated [respondent's] employment decision." 3 id., at 90, 152. 3 Record 20-22; 4 id., at 335. For instance, while acknowledging "the potentially damning nature" of Chesnut's age-related comments, the court discounted them on the ground that they "were not made in the direct context of Reeves's termination." For purposes of this case, we need not--and could not--resolve all of the circumstances in which such factors would entitle an employer to judgment as a matter of law. 4 Record 197-199. 2. 1. Petitioner testified that his job only included reviewing the daily and weekly attendance reports, and that disciplinary writeups were based on the monthly reports, which were reviewed by Caldwell. Tr. See id., at 693-694. This much is evident from our decision in St. Mary's Honor Center. Accordingly, "the McDonnell Douglas framework--with its presumptions and burdens"--disappeared, St. Mary's Honor Center, supra, at 510, and the sole remaining issue was "discrimination vel non," Aikens, supra, at 714. A 1994 letter authored by Chesnut indicated that he berated other company directors, who were supposedly his co-equals, about how to do their jobs. Reeves' responsibilities included recording the attendance and hours worked by employees under his supervision. You have successfully signed up to receive the Casebriefs newsletter. 29 U. S. C. §623(a)(1). Pp. Ibid. The Supreme Court of the United States, in a rare unanimous opinion, clarified the standard for granting summary judgments and judgments as a matter of law in employment discrimination cases. And the court discredited Reeves' evidence that Chesnut was the actual decisionmaker by giving weight to the fact that there was no evidence suggesting the other decisionmakers were motivated by age. Petitioner, however, made a substantial showing that respondent's explanation was false. Sanderson testified that she accepted the recommendation to discharge petitioner because he had "intentionally falsif[ied] company pay records." 475 U. S. 574, 587 (1986). In this case, it suffices to say that a plaintiff's prima facie case, combined with sufficient evidence to find that the employer's asserted justification is false, may permit the trier of fact to conclude that the employer unlawfully discriminated. Moreover, once the employer's justification has been eliminated, discrimination may well be the most likely alternative explanation, especially since the employer is in the best position to put forth the actual reason for its decision. Moreover, although the presumption of discrimination "drops out of the picture" once the defendant meets its burden of production, St. Mary's Honor Center, supra, at 511, the trier of fact may still consider the evidence establishing the plaintiff's prima facie case "and inferences properly drawn therefrom ... on the issue of whether the defendant's explanation is pretextual," Burdine, supra, at 255, n. 10. Ibid. This Court has not squarely addressed whether the McDonnell Douglas framework, developed to assess claims brought under §703(a)(1) of Title VII of the Civil Rights Act of 1964, 78 Stat. 4 id., at 244. In October 1995, petitioner Roger Reeves was 57 years old and had spent 40 years in the employ of respondent, Sanderson Plumbing Products, Inc., a manufacturer of toilet seats and covers. INTRODUCTION Title VII of the Civil … Chesnut conducted that efficiency study and, after having testified to the contrary on direct examination, acknowledged on cross-examination that he had recommended that petitioner be placed on probation following the study. Petitioner also testified that, on the day he was fired, Chesnut said that his discharge was due to his failure to report as absent one employee, Gina Mae Coley, on two days in September 1995. Based on this evidence, the Court of Appeals concluded that petitioner "very well may be correct" that "a reasonable jury could have found that [respondent's] explanation for its employment decision was pretextual." I write separately to note that it may be incumbent on the Court, in an appropriate case, to define more precisely the circumstances in which plaintiffs will be required to submit evidence beyond these two categories in order to survive a motion for judgment as a matter of law. CERTIORARI TO THE UNITED STATES COURT OF APPEALS … Nos. Industrial Co. v. Zenith Radio Corp., 475 U. S. 574, 587, drawing all reasonable inferences in favor of the nonmoving party, but making no credibility determinations or weighing any evidence, e.g., Lytle v. Household Mfg., Inc., 494 U. S. 545, 554-555. Under McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973), a plaintiff alleging intentional discrimination under the ADEA or Title VII, must make a prima facie case for discrimination. Finally, petitioner stated that on previous occasions that employees were paid for hours they had not worked, the company had simply adjusted those employees' next paychecks to correct the errors. U.S. Reports: Reeves v. Sanderson Plumbing Products, Inc., 530 U.S. 133 (2000). 14-16. But both petitioner and Oswalt testified that the company's automated timeclock often failed to scan employees' timecards, so that the timesheets would not record any time of arrival. denied, 521 U. S. 1129 (1997); Gaworski v. ITT Commercial Finance Corp., 17 F. 3d 1104 (CA8) (same), cert. 197 F. 3d, at 693. denied, 504 U. S. 985 (1992); Ackerman v. Diamond Shamrock Corp., 670 F. 2d 66, 69 (CA6 1982). Respondent met this burden by offering admissible evidence sufficient for the trier of fact to conclude that petitioner was fired because of his failure to maintain accurate attendance records. Again, the court disregarded critical evidence favorable to petitioner--namely, the evidence supporting petitioner's prima facie case and undermining respondent's nondiscriminatory explanation. As a pre-law student you are automatically registered for the Casebriefs™ LSAT Prep Course. Petitioner worked in a department known as the "Hinge Room," where he supervised the "regular line." Under Rule 50, a court should render judgment as a matter of law when "a party has been fully heard on an issue and there is no legally sufficient evidentiary basis for a reasonable jury to find for that party on that issue." " St. Mary's Honor Center, supra, at 524 (quoting Aikens, 460 U. S., at 716). O'Connor, J., delivered the opinion for a unanimous Court. On this basis, the court concluded that petitioner had not introduced sufficient evidence for a rational jury to conclude that he had been discharged because of his age. It suffices to say that, because a prima facie case and sufficient evidence to reject the employer's explanation may permit a finding of liability, the Court of Appeals erred in proceeding from the premise that a plaintiff must always introduce additional, independent evidence of discrimination. of Ed., 202 F. 3d 636, 639 (CA2 2000); Hall v. Giant Food, Inc., 175 F. 3d 1074, 1077-1078 (CADC 1999); Beaird v. Seagate Technology Inc., 145 F. 3d 1159, 1165 (CA10), cert. 197 F. 3d, at 690. Whether judgment as a matter of law is appropriate in any particular case will depend on a number of factors. After noting respondent's proffered justification for petitioner's discharge, the court acknowledged that petitioner "very well may" have offered sufficient evidence for "a reasonable jury [to] have found that [respondent's] explanation for its employment decision was pretextual." And in making this determination, the Court of Appeals ignored the evidence supporting petitioner's prima facie case and challenging respondent's explanation for its decision. Lytle v. Household Mfg., Inc., 494 U. S. 545, 554-555 (1990); Liberty Lobby, Inc., supra, at 254; Continental Ore Co. v. Union Carbide & Carbon Corp., 370 U. S. 690, 696, n. 6 (1962). denied, 513 U. S. 946 (1994); Anderson v. Baxter Healthcare Corp., 13 F. 3d 1120 (CA7 1994) (same); Washington v. Garrett, 10 F. 3d 1421 (CA9 1993) (same), with Aka v. Washington Hospital Center, 156 F. 3d 1284 (CADC 1998) (en banc) (plaintiff's discrediting of employer's explanation is entitled to considerable weight, such that plaintiff should not be routinely required to submit evidence over and above proof of pretext), and with Fisher v. Vassar College, 114 F. 3d 1332 (CA2 1997) (en banc) (plaintiff must introduce sufficient evidence for jury to find both that employer's reason was false and that real reasonwas discrimination), cert. This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. Ibid. Such a showing by the plaintiff will not always be adequate to sustain a jury's liability finding. Petitioner introduced evidence that he had accurately recorded the attendance and hours of the employees under his supervision, and that Chesnut, whom Oswalt described as wielding "absolute power" within the company, 3 Record 80, had demonstrated age-based animus in his dealings with petitioner. ; see also St. Mary's Honor Center, supra, at 507-508. Ante, at 12. See 9A C. Wright & A. Miller, Federal Practice and Procedure §2529, pp. 14,000 + case briefs, hundreds of Law Professor developed 'quick' Black Letter Law. Yet respondent conducted an efficiency study of only the regular line, supervised by petitioner, and placed only petitioner on probation. This Court need not--and could not--resolve all such circumstances here. Most of the timekeeping errors cited by respondent involved employees who were not marked late but who were recorded as having arrived at the plant at 7 a.m. for the 7 a.m. shift. See Furnco, 438 U. S., at 580 (evidence that employer's work force was racially balanced, while "not wholly irrelevant," was not "sufficient to conclusively demonstrate that [the employer's] actions were not discriminatorily motivated"). 99–536. All rights reserved. ed. REEVES v. SANDERSON PLUMBING PRODUCTS, INC. CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT No. Proof that the defendant's explanation is unworthy of credence is simply one form of circumstantial evidence that is probative of intentional discrimination, and it may be quite persuasive. Your Study Buddy will automatically renew until cancelled. Reeves brought suit against Sanderson Plumbing Prods. The District Court denied respondent's motions for judgment as a matter of law under Federal Rule of Civil Procedure 50, and the case went to the jury, which returned a verdict for Reeves. In so reasoning, the court misconceived the evidentiary burden borne by plaintiffs who attempt to prove intentional discrimination through indirect evidence. He and Sanderson also stated that petitioner's errors, by failing to adjust for hours not worked, cost the company overpaid wages. Reeves' duties included making sure workers under his supervision were on time and at work and logging such data. Applying this standard here, it is apparent that respondent was not entitled to judgment as a matter of law. REEVES v. SANDERSON PLUMBING PRODUCTS, INC. certiorari to the united states court of appeals for the fifth circuit No. Respondent contended that employees arriving at 7 a.m. could not have been at their workstations by 7 a.m., and therefore must have been late. In 1995, Chesnut ordered another investigation of the Hinge Room, which, according to his testimony, revealed that petitioner was not correctly recording the absences and hours of employees. Oswalt, roughly 24 years younger than petitioner, corroborated that there was an "obvious difference" in how Chesnut treated them. Ginsburg, J., filed a concurring opinion. Although Sanderson testified that she fired petitioner because he had "intentionally falsif[ied] company pay records," 3 id., at 100, respondent only introduced evidence concerning the inaccuracy of the records, not their falsification. Internet Explorer 11 is no longer supported. Nonetheless, the court held that this showing, standing alone, was insufficient to sustain the jury's finding of liability: "We must, as an essential final step, determine whether Reeves presented sufficient evidence that his age motivated [respondent's] employment decision." 2 Record, Doc. Because the monthly attendance reports did not indicate a problem, Chesnut ordered an audit, which, according to his testimony, revealed numerous timekeeping errors and misrepresentations by Caldwell, Reeves, and Oswalt. A plaintiff's prima facie case of discrimination (as defined in McDonnell Douglas Corp. v. Green, 411 U. S. 792, 802, and subsequent decisions), combined with sufficient evidence for a reasonable factfinder to reject the employer's nondiscriminatory explanation for its decision, may be adequate to sustain a finding of liability for intentional discrimination under the ADEA. A link to your Casebriefs™ LSAT Prep Course Workbook will begin to download upon confirmation of your email 255, 42 U. S. C. §2000e-2(a)(1), also applies to ADEA actions. See Furnco, supra, at 580. Petitioner testified that Chesnut had told him that he "was so old [he] must have come over on the Mayflower" and, on one occasion when petitioner was having difficulty starting a machine, that he "was too damn old to do [his] job." In so reasoning, the Court of Appeals misconceived the evidentiary burden borne by plaintiffs who attempt to prove intentional discrimination through indirect evidence. Yes. See 197 F. 3d, at 693. Id., at 524. See App. It therefore follows that, in entertaining a motion for judgment as a matter of law, the court should review all of the evidence in the record. And in attempting to satisfy this burden, the plaintiff--once the employer produces sufficient evidence to support a nondiscriminatory explanation for its decision--must be afforded the "opportunity to prove by a preponderance of the evidence that the legitimate reasons offered by the defendant were not its true reasons, but were a pretext for discrimination." Respondent was not entitled to judgment as a matter of law under the particular circumstances presented here. That is, the plaintiff's age must have "actually played a role in [the employer's decisionmaking] process and had a determinative influence on the outcome." Is no longer supported to select standard for judgment as a matter of law the... 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