McDonnell Douglas Corp. v. Green

Summary

The Supreme Court addresses the order and allocation of proof in a private employment-discrimination action under Title VII of the Civil Rights Act of 1964. It holds that a claimant may establish a prima facie case of racial discrimination, after which the employer must articulate a legitimate, nondiscriminatory reason for its decision; the claimant must then have an opportunity to show that the reason is pretextual. The Court vacated and remanded for further proceedings concerning the respondent's racial-discrimination claim.

Holdings

1. A complainant who timely files discrimination charges with the EEOC and receives and acts upon the statutory notice of the right to sue may bring a Title VII action even if the Commission has made no reasonable-cause determination.
2. The complainant initially bears the burden of establishing a prima facie case by showing that he belongs to a racial minority, applied and was qualified for a position for which the employer sought applicants, was rejected despite his qualifications, and that the position remained open while the employer continued seeking similarly qualified applicants.
3. After the complainant establishes a prima facie case, the burden shifts to the employer to articulate some legitimate, nondiscriminatory reason for the rejection.
4. Even when an employer identifies unlawful conduct as a legitimate reason for refusing to rehire, the applicant must be given a fair opportunity to prove that the stated reason was pretextual or was applied discriminatorily; an employer may rely on the criterion only if it is applied alike to members of all races.

Questions Presented

1. Whether an EEOC reasonable-cause determination is a prerequisite to bringing a Title VII racial-discrimination claim in federal court.
2. What order and allocation of proof govern a private, non-class Title VII action alleging discriminatory refusal to hire or rehire.
3. Whether an employer may rely on an applicant's unlawful conduct directed against the employer as a legitimate, nondiscriminatory reason for refusing to rehire, subject to proof that the reason was a pretext or was applied discriminatorily.

Disposition

vacated