Supreme Court Says Pretext Alone Is Sufficient Basis For Proving Discrimination
In a unanimous decision issued in June 2000,
the U.S. Supreme Court clarified the standard for proving discrimination
claims filed under federal law.† The Court held that a jury may find in
favor of a plaintiff claiming age discrimination if the plaintiff merely shows
that the employer's stated reason for his termination was false.† In
reversing a decision by the Fifth Circuit Court of Appeals, the Supreme Court
reiterated a rule it established seven years ago, but that had not always been
strictly followed in the lower federal courts: proof that an employer's
reasons for a termination are a pretext may, by itself, be sufficient to
permit a jury to find discriminatory intent, even if there is no other
evidence of discrimination.† The decision highlights the importance of
documenting employee performance problems as a means of avoiding
discrimination claims.
The plaintiff in the case, Roger Reeves, was
57 years old at the time he was fired and had worked for Sanderson Plumbing
Products, a toilet seat manufacturer, for 40 years.† The company claimed
it discharged Reeves mainly because he had incorrectly recorded absences and
tardiness in the department he supervised and had failed to discipline
employees who were absent or late.† Sanderson also pointed out that it
had terminated a younger employee at the same time it fired Reeves and that
the company employed a number of managers who were over the age of 50.
In response, Reeves offered evidence that his
record-keeping had been accurate and that he was not responsible for
disciplining employees for violations of the attendance policy.† Reeves
also testified that one of the managers who recommended his firing had told
him that he was ìtoo damn old to do the jobî and that he was so old that
he ìmust have come over on the Mayflower.î† A co-worker testified
that the manager had treated Reeves more harshly than younger employees.
A jury found that Sanderson fired Reeves
because of his age and awarded him nearly $100,000 in damages, but the Fifth
Circuit Court of Appeals reversed the jury's verdict.† The Court of
Appeals held that there was insufficient evidence at trial to prove
discrimination.† Specifically, the Fifth Circuit found that a reasonable
jury might have concluded that Sanderson's reasons for firing Reeves were
pretextual, but that there was not enough evidence to show that those reasons
were a pretext for age discrimination.†
The Supreme Court reinstated the verdict in
favor of Reeves...
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