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In United States employment discrimination law, McDonnell Douglas burden-shifting or the McDonnell-Douglas burden-shifting framework refers to the procedure for adjudicating a motion for summary judgement under a Title VII disparate treatment claim, in particular a "private, non-class action challenging employment discrimination", [1] that lacks direct evidence of discrimination.
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973), is a US employment law case by the United States Supreme Court regarding the burdens and nature of proof in proving a Title VII case and the order in which plaintiffs and defendants present proof. It was the seminal case in the McDonnell Douglas burden-shifting framework.
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). [1]
This framework, known as the McDonnell Douglas burden-shifting analysis, is now used by federal courts to interpret employment discrimination claims where no direct evidence of discriminatory intent can be found. [2] In 2009, the Supreme Court issued its opinion on Gross v. FBL Financial Services, Inc.. In a 5-4 opinion, the Court ruled that ...
The trial court granted summary judgment to the Department because it found Muldrow did not suffer a materially adverse action and thus failed to satisfy the "adverse employment action" prong in the McDonnell Douglas burden-shifting framework. [11] The United States Court of Appeals for the Eighth Circuit affirmed. [12]
She then turned to the next stage of the McDonnell Douglas burden-shifting framework to determine whether the defendant had then provided adequate evidence that the employment decision in question had been made for "a legitimate, nondiscriminatory reason." [6] That burden, too, was met, according to O'Connor's analysis.
Swierkiewicz v. Sorema N. A., 534 U.S. 506 (2002), was a case decided by the Supreme Court of the United States on February 26, 2002. The Court held that for complaints in employment discrimination cases, a plaintiff is not required to allege specific facts that establish a prima facie case as required by the McDonnell Douglas burden-shifting framework.
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986), is a United States Supreme Court case articulating the standard for a trial court to grant summary judgment.Summary judgment will lie when, taking all factual inferences in the non-movant's favor, there exists no genuine issue as to a material fact and the movant deserves judgment as a matter of law.