St. Mary's Honor Center v. Hicks

St. Mary's Honor Center v. Hicks, 509 U.S. 502 (1993), was a US labor law case before the United States Supreme Court on the burden of proof and the relevance of intent for race discrimination.

Hicks, who was a black employee of St. Mary's Honor Center, a halfway house operated by the Missouri department of corrections and human resources, claimed race discrimination when he was demoted and discharged under the Civil Rights Act of 1964 §2000e-2(a)(1).

The District Court (Stephen N. Limbaugh Sr.), found that (1)(a) the employee had established a prima facie case of racial discrimination, and (b) the reasons that the employer gave for the demotion and discharge were not the real reasons for the demotion and discharge, but that (2) the employee had failed to carry his ultimate burden of proving that his race was the determining factor in the employer's allegedly discriminatory actions.

Whereas we said in Burdine that if the employer carries its burden of production, "the factual inquiry proceeds to a new level of specificity," 450 U.S., at 255, 101 S.Ct., at 1095, the Court now holds that the further enquiry is wide open, not limited at all by the scope of the employer's proffered explanation.10 Despite the Court's assiduous effort to reinterpret our precedents, it remains clear that today's decision stems from a flat misreading of Burdine and ignores the central purpose of the McDonnell Douglas framework, which is "progressively to sharpen the inquiry into the elusive factual question of intentional discrimination."

We have repeatedly identified the compelling reason for limiting the factual issues in the final stage of a McDonnell Douglas case as "the requirement that the plaintiff be afforded a full and fair opportunity to demonstrate pretext."

The majority fails to explain how the plaintiff, under its scheme, will ever have a "full and fair opportunity" to demonstrate that reasons not articulated by the employer, but discerned in the record by the factfinder, are also unworthy of credence.

Burdine provides the answer, telling us that such a plaintiff may succeed in meeting his ultimate burden of proving discrimination "indirectly by showing that the employer's proffered explanation is unworthy of credence."

The possibility of some practical procedure for addressing what Burdine calls indirect proof is crucial to the success of most Title VII claims, for the simple reason that employers who discriminate are not likely to announce their discriminatory motive.

While the Court appears to acknowledge that a plaintiff will have the task of disproving even vaguely suggested reasons, and while it recognizes the need for "[c]larity regarding the requisite elements of proof," ante, at ____, it nonetheless gives conflicting signals about the scope of its holding in this case.

But other language in the Court's opinion supports a more extreme conclusion, that proof of the falsity of the employer's articulated reasons will not even be sufficient to sustain judgment for the plaintiff.