Brief Fact Summary. Petitioner, Texas Department of Community Affairs, challenged the evidentiary burden ordered by the Court of Appeals for the Fifth Circuit that Petitioner must prove by the preponderance of the evidence that there was a nondiscriminatory reason for the firing of Respondent, Burdine.
Synopsis of Rule of Law. The plaintiff has the burden of establishing a prima facie case of discrimination, and if the defendant can articulate a legitimate nondiscriminatory reason for the conduct then the burden falls back to the plaintiff to prove by a preponderance of the evidence that the reasons put forth by the defendant were just a pretext for discrimination.
By applying McDonnell Douglas's shifting burdens of production in the context of a motion for summary judgment, the judge will determine whether the litigants have created an issue of fact to be decided by the jury.View Full Point of Law
Issue. The issue is whether the Defendant has the burden to prove by the preponderance of the evidence that their practices are nondiscriminatory.
Held. The United States Supreme Court held that the Appellate Court’s evidentiary burden was incorrect and they remanded the case. The Court reiterated the burden laid out in McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973), which is to place the burden first on Plaintiff to establish a prima facie case of discrimination, and then put the burden on Defendant to offer a nondiscriminatory explanation for their practices. If Defendant meets this burden, then the burden shifts back to Plaintiff to prove by a preponderance of the evidence that Defendant’s explanation is false.
Discussion. In McDonnell Douglas, the plaintiff was claiming racial discrimination, and the Court here furthered the reasoning in that case but elaborated on what it takes to shift the burden between Defendant and Plaintiff.