Texas Department of Community Affairs v. Burdine

Summary

The Supreme Court addressed the allocation of evidentiary burdens in a Title VII employment-discrimination case after a plaintiff establishes a prima facie case. It held that the defendant bears only a burden of production to articulate clear, admissible, legitimate nondiscriminatory reasons for the challenged action, while the ultimate burden of persuasion remains with the plaintiff.

Holdings

1. After a Title VII plaintiff establishes a prima facie case of discrimination, the defendant bears only a burden of production, not the burden of persuading the court by a preponderance of the evidence, to articulate and clearly set forth admissible evidence of legitimate, nondiscriminatory reasons for the challenged employment action.
2. The employer's explanation must be clear and reasonably specific and must be supported by admissible evidence sufficient to permit the trier of fact rationally to conclude that the employment decision was not motivated by discriminatory animus.
3. Title VII does not require the employer to prove by objective comparative evidence that the person selected was more qualified than the plaintiff in order to satisfy the employer's intermediate burden.

Questions Presented

1. After a Title VII plaintiff establishes a prima facie case of disparate treatment, must the defendant prove by a preponderance of the evidence that legitimate, nondiscriminatory reasons existed for the challenged employment action?
2. Must a Title VII defendant provide objective comparative evidence proving that the person hired or retained was better qualified than the plaintiff?
3. What evidentiary burden does the defendant bear under the McDonnell Douglas framework after the plaintiff establishes a prima facie case?

Disposition

vacated