Respondent Melvin Hicks, a black man, was hired as a correctional officer at St. Mary’s in August 1978 and was promoted to shift commander, one of six supervisory positions, in February 1980. Audio Transcription for Oral Argument - April 20, 1993 in St. Mary's Honor Center v. Hicks Gary L. Gardner:--If we can distinguish in the steps of the case. In St. Mary's Honor Center v. Hicks, the Supreme Court held that a plaintiff in an employment discrimination suit must prove both a ... positions is significant. prepared by the Reporter of Decisions for the convenience of the reader. petitioners in the same position as if they had remained silent in the 2. 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. Litigation: St. Mary's Honor Center v. Hicks, Pretext, and the "Personality" Excuse Mark S. Brodin* Since the enactment of Title VII of the Civil Rights Act of 1964 the After that, Hicks began to be singled out for reprimands, was demoted, and eventually was fired. ST. MARY'S HONOR CENTER et al. 3. Scalia, J., delivered the opinion of the Court, in which Rehnquist, In setting Id. 92-602 . v. Hicks' is a Title VIW2 discharge case which, at first blush, seems to severely limit the framework set out in McDonnell Douglas Corp. v. Green3 for proving unlawful discrimina- … Three years later a state mandated examination was conducted which brought about broad authoritative modifications the following year. v. Hicks, 509 U.S. 502 (1993). v. Hicks Call Number/Physical Location Call Number: KF101 1991). Texas Dept. Pp. After being demoted and does not shift the burden of proof, and would ignore the admonition St. Mary’s Honor Center v. Hicks, 1 the United States Supreme Court revisited its landmark 1973 decision, McDonnell Douglas Corp. v. Green. The Court thus transforms the employer's burden of production from a device used to provide notice and promote fairness into a misleading and potentially useless ritual. v. Hicks, 113 S. Ct. 2742, 2757 (1993) (Souter, J., dissenting) (stating that "[tihe language of Title VII . Hicks v. St. Mary's Honor Ctr., No. The Demise of Circumstantial Proof in Employment Discrimination Litigation: St. Mary's Honor Center v. Hicks, Pretext, and the 'Personality' Excuse January 1997 at 1250. Argued April 20, 1993—Decided June 25, 1993 Petitioner halfway house employed respondent Hicks as a correctional of-ficer and later a … No. him because of his race. Id., at 255, n. 8, 101 S.Ct., at 1094, n. 8. BACKGROUND A. Respondent Melvin Hicks, a black man, was hired as a correctional officer at St. Mary's in August 1978 and was promoted to shift commander, one of six supervisory positions, in February 1980. The Seventh Circuit has held in one case that where the defendant asserts several reasons for its decision, the plaintiff may not normally survive summary judgment by refuting only one of the reasons. C. J., and O'Connor, Kennedy, and Thomas, JJ., joined. 1994) case opinion from the US Court of Appeals for the Eighth Circuit [2], The United States Court of Appeals for the Eighth Circuit reversed and remanded, holding that, once the employee had proved all of the employer's proffered reasons for the adverse employment actions to be pretextual, the employee was entitled to judgment as a matter of law. employer for alleged discriminatory employment practices unless the Citation 509 US 502 (1993) Argued. ultimately persuasive or not, satisfied their burden of production and (c) The concerns of the dissent and respondent that this decision St. Mary's Honor Center v. Hicks. Oral Argument - April 20, 1993; Opinions. preponderance of the evidence, a prima facie case of racial 92-602, St. Mary’s Honor Center v. Melvin Hicks. presentation of proof in Title VII discriminatory treatment cases that Citation 509 US 502 (1993) Argued. . Respondent Melvin Hicks, a black man, was hired as a correc= tional officer at St. Mary=E2=80=99s in August 1978 and was promoted to shi= ft commander, one of six supervisory positions, in February 1980. v. Hicks, 113 S. Ct. 2742, 2745 (1993). 1997). Id. 2-22. JJ., joined. Respondent Hicks . 301, the ultimate burden of persuasion remained at all times Age Discrimination in Employment Act of 1967, Texas Dept of Community Affairs v Burdine, International Brotherhood of Teamsters v US, General Telephone Co of Southwest v Falcon, Title VII of the Civil Rights Act of 1964, List of United States Supreme Court cases, volume 509, List of United States Supreme Court cases, Lists of United States Supreme Court cases by volume, List of United States Supreme Court cases by the Rehnquist Court, https://en.wikipedia.org/w/index.php?title=St._Mary%27s_Honor_Center_v._Hicks&oldid=982031324, United States Supreme Court cases of the Rehnquist Court, United States employment discrimination case law, Creative Commons Attribution-ShareAlike License. To demonstrate discrimination, an employee must conform under Title VII of the Civil Rights Act of 1964 (Cundiff, & Chaitovitz, 1994). of Governors v. Oral Argument - April 20, 1993. U.S. Reports: St. Mary's Honor Ctr. In St. Mary’s Honor Center v. Hicks, the Supreme Court considered a race discrimination under Title VII and resolved a circuit split referred to as the pretext-only v. pretext-plus debate. to disbelieve the employer." Melvin Hicks appeals from a final judgment entered in the United States District Court1 for the Eastern District of Missouri in favor of his former employer, St. Mary's Honor Center (St. Mary's), and the superintendent of St. Mary's, Steve Long (together defendants), on his claims arising under Title VII and the equal protection clause. Nor may the Court substitute for that required St. Mary's Honor Center v. Hicks. Coco v. Elmwood Care, Inc., 128 F.3d 1177, 1178 (7th Cir. their actions; and that petitioners' reasons were pretextual. 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." Lower court United States Court of Appeals for the Eighth Circuit . being done in connection with this case, at the time the opinion is issued. ST. MARY'S HONOR CENTER V. HICKS: QUESTIONING THE BASIC ASSUMPTION Deborah A. Calloway* [Tihe prima facie case "raises an inference of discrimina-tion ... because we presume these acts, if otherwise unex- plained, are more likely than not based on the consideration of impermissible factors."' petitioners came forward with an explanation. Oral Argument - April 20, 1993; Opinions. 2 McDonnell Douglas established a tripartite burden-shifting analysis for proving intentional discrimination by the employer, that is, for In a suit against an employer alleging intentional racial discrimination in violation of Title VII, trier of fact's rejection of employer's asserted reasons for its actions does not compel judgment for plaintiff. Three years later a state mandated examination was conducted which brought about broad authoritative modifications the … The same view is implicit in the Court's decision to remand this case, ante, at ____, keeping Hicks's chance of winning a judgment alive although he has done no more (in addition to proving his prima facie case) than show that the reasons proffered by St. Mary's are unworthy of credence. 9-17. St. Mary’s Honor Center v. Hicks The St. Mary’s Center v. Hicks case created national storm after the Supreme Court decision that an employee must provide evidence and prove discrimination in the workplace. CASE ANALYSIS: (1993) ST. MARY’S HONOR CENTER V. HICKS 3 The reasons didn’t have to necessarily be persuasive, they just had to be able support the idea of intentional discrimination. The St. Mary’s Center v. Hicks case created national storm after the Supreme Court decision that an employee must provide evidence and prove discrimination in the workplace. . v. HICKS certiorari to the united states court of appeals for the eighth circuit. Saint Mary's Center is a correctional facility. 2. employer's explanation of its action was not believable. 2 McDonnell Douglas established a tripartite burden-shifting analysis for proving intentional discrimination by the employer, that is, for proving disparate treatment, in those cases where no direct evidence of liability is available. ultimately discharged, Hicks filed suit, alleging that these actions 92-602 . Mr. Hicks was contracted as a prison guard at the institution August 1978 and was elevated to the position of supervisor in 1980. Rather, plaintiffs must somehow prove that the pretext was offered to hide discrimination, and not for some other motivation. 1244 — Brought to you by Free Law Project, a non-profit dedicated to creating high quality open legal information. The Court repeats the truism that the plaintiff has the "ultimate burden" of proving discrimination, see ante, at ____, ____, without ever facing the practical question of how the plaintiff without such direct evidence can meet this burden. Argued April 20, 1993-- Decided June 25, 1993. Mr. Hicks was contracted as a prison guard at the institution August 1978 and was elevated to the position of supervisor in 1980. Adhering to the 92-602. ST. MARY’S HONOR CENTER et al. Hicks v. St. Mary's Honor Ctr., St. Mary's Honor Center v. Hicks, 509 U.S. at 511; Anderson v. Baxter Healthcare Corp., 13 F.3d 1120, 1123 (7th Cir. Evid. Advocates. eliminated by United States Postal Service Bd. filed a dissenting opinion, in which White, Blackmun, and Stevens, 83 The two reasons offered by St. Mary's for Hicks's termination were "the severity and the accumulation of violations committed by plaintiff." Syllabus ; View Case ; Petitioner St. Mary's Honor Center et al. Melvin Hicks was hired as a correctional officer at St. Mary's in August 1978 and was promoted to a supervisory position, shift commander, in February 1980. The majority's scheme greatly disfavors Title VII plaintiffs without the good luck to have direct evidence of discriminatory intent. Petitioners' was one of the most controversial decisions the Court handed down in a largely low-key 1992-93 term. The prohibitions against discrimi-nation contained in the Civil Rights Act of 1964 reflect an important national policy. Brewer v. Quaker State Oil Riifining Co. Discrediting the reasons offered by the employer for its decision no longer suffices to establish a violation of Title VII. explanation is alone enough to sustain a plaintiff's case was Souter J dissented (joined by White, Blackmun, and Stevens), arguing an employer would be better off presenting an untruthful explanation of its actions than presenting none at all. In one passage, the Court states that although proof of the falsity of the employer's proffered reasons does not "compe[l] judgment for the plaintiff," such evidence, without more, "will permit the trier of fact to infer the ultimate fact of intentional discrimination." 1244, 1252 (E.D. of Community Affairs v. Burdine, 450 U.S. 248, 252-253, had been taken because of his race in violation of, inter alia, St. Mary's Honor Center is a halfway house operated by the Missouri Department of Corrections and Human Resources. § 2000e, and Long had violated 42 U.S.C. Petitioner halfway house employed respondent Hicks as a correctional officer and later a shift commander. Audio Transcription for Oral Argument – April 20, 1993 in St. Mary’s Honor Center v. Hicks William H. Rehnquist: We’ll hear argument next in No. 3 . Apr 20, 1993. Brewer v. Quaker State Oil Riifining Co. St. Mary’s Honor Center v. Hicks, 509 U.S. 502 (1993) The Defendant was a halfway house that employed the Plaintiff, Hicks, as a correctional officer. The Note begins with a brief review of the case law governing the burden of proof and then outlines the facts and procedural history of the Hicks case, including both the majority and dissenting opinions. that the Title VII plaintiff at all times bears the ultimate burden of Id., at 258, 101 S.Ct., at 1096 (internal quotation marks omitted); see id., at 256, 101 S.Ct., at 1095 (the plaintiff "must have the opportunity to demonstrate" pretext); Aikens, supra, at 716, n. 5, 103 S.Ct., at 1482; Furnco, 438 U.S., at 578, 98 S.Ct., at 2950; McDonnell Douglas, 411 U.S., at 805, 93 S.Ct., at 1825-1826. Carter v. Duncan-Huggins, Ltd., 234 U.S.App.D.C. Ante, at ____ (emphasis in original). In Hicks, the Court reaffirmed what it had said in United States Postal Services Board of Governors v. Aikens, 460 U.S. 711, 716 (1983): [Tihe question facing triers of fact in discrimination cases is both sensi-tive and difficult. McDonnell Douglas framework then became irrelevant, and the trier 82 Hicks v. St. Mary's Honor Center, 756 F. Supp. Ante, at ____ (emphasis omitted). Rappaport: St. Mary's Honor Center v. Hicks: Has the Supreme Court Turned It Published by Villanova University Charles Widger School of Law Digital Repository, 1994. 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). 88-109C(5) (E.D. 92-602 . Media. Id. Coco v. Mo. And yet, under the majority's scheme, a victim of discrimination lacking direct evidence will now be saddled with the tremendous disadvantage of having to confront, not the defined task of proving the employer's stated reasons to be false, but the amorphous requirement of disproving all possible nondiscriminatory reasons that a factfinder might find lurking in the record. Docket no. Id., at 254-255, In Blare v. Husky, which involved a claim for age discrimination, the SJC explicitly departed from the Supreme Court’s ruling in St. Mary’s Honor Center v. Hicks and confirmed that Massachusetts is a “pretext-only” jurisdiction. ST. MARY’S HONOR CENTER et al. St. Mary's Honor Center v. Hicks, 509 U.S. at 511; Anderson v. Baxter Healthcare Corp., 13 F.3d 1120, 1123 (7th Cir. officer and later a shift commander. Melvin Hicks appeals from a final judgment entered in the United States District Court 1 for the Eastern District of Missouri in favor of his former employer, St. Mary's Honor Center (St. Mary's), and the superintendent of St. Mary's, Steve Long (together defendants), on his claims arising under Title VII and the equal protection clause. St. Mary’s Honor Center introduced two legitimate pieces of evidence of nondiscriminatory reasons for Hick’s termination. v. HICKS certiorari to the united states court of appeals for the eighth circuit No. was one of the most controversial decisions the Court handed down in a largely low-key 1992-93 term. finding the much different and much lesser finding that the Jun 25, 1993. In St. Mary's Honor Center v. Hicks, a closely-divided Supreme Court substantially altered the McDonnell Douglas framework. . Decided . proving that the adverse actions were racially motivated. . In St. Mary's Honor Center v. Hicks, a closely-divided Supreme Court substantially altered the McDonnell Douglas framework. preponderance of the evidence, a prima facie case of discrimination, St. Mary's Honor Center v. Hicks. 450 U.S., at 256, 10 S.Ct., at 1095; see Aikens, supra, at 716, 103 S.Ct., at 1482; id., at 717-718, 103 S.Ct., at 1482-1483 (BLACKMUN, J., joined by Brennan, J., concurring). 2d 407 (1993), rev'g and remanding, 970 F.2d 487 (8th Cir. rebutted the presumption of intentional discrimination. Argued April 20, 1993—Decided June 25, 1993 Petitioner halfway house employed respondent Hicks as a correctional of-ficer and later a shift commander. The Court remains in session. Jun 25, 1993. Discrediting the reasons offered by the employer for its decision no longer suffices to establish a violation of Title VII. 1 . The Supreme Court's decision in St. Mary's Honor Center v. Hicks. The decision de- which, if believed by the trier of fact, would support a finding that with Hicks, id., at 253. Melvin Hicks, Appellant, v. St. Mary's Honor Center, Division of Adult Institutions Ofthe Department of Corrections and Human Resourcesof the State of Missouri; Steve Long, Appellees, 2 F.3d 265 (8th Cir. Lower court United States Court of Appeals for the Eighth Circuit . Respondent Hicks . L. Rev. VILLANOVA LAW REVIEW. discrimination; that petitioners had rebutted that presumption by Advocates. is no longer relevant." St. Mary's Honor Center v. Hicks, --- U.S. ----, 113 S. Ct. 2742, 125 L. Ed. See United States v. Detroit Lumber Co., 200 U.S. 321, 337. 1244 (E.D. unlawful discrimination did not cause their actions. Lower court United States Court of Appeals for the Eighth Circuit . Scalia, joined by Rehnquist, O'Connor, Kennedy, Thomas, Souter, joined by White, Blackmun, Stevens, This page was last edited on 5 October 2020, at 20:09. 5. He said the majority's approach was "inexplicable in forgiving employers who present false evidence in court". For the reasons discussed below, we remand the case to the district court for further consideration in light of the Supreme Court's opinion. Any doubt 1244 (E.D.Mo.1991). . Decided . makes plain the purpose of Congress to assure equality of employment opportunities and to eliminate those discriminatory practices persuasion. Syllabus ; View Case ; Petitioner St. Mary's Honor Center et al. have to introduce some evidence . . This presumption 1287 (1996). St. Mary's Honor Center v. Hicks 113 S. Ct. 2742 (1993) Justice Scalia delivered the opinion of the Court. its actions does not entitle a plaintiff to judgment as a matter of law. (a) Under McDonnell Douglas, once Hicks established, by a Respondent Hicks . - Description: U.S. Reports Volume 509; October Term, 1992; St. Mary's Honor Center et al. Docket no. Rule Melvin Hicks, an African American, was discharged from his job as a shift commander at St. Mary's Honor Center correctional facility, allegedly because of numerous deficiencies in his job performance, including threatening his immediate supervisor, John Powell, during a For the majority, Scalia J held (joined by Rehnquist, O'Connor, Kennedy, and Thomas) even if a plaintiff discredits an employer’s explanation, the employer can still win if the trier of fact concludes there was no discriminatory intent. ST. MARY'S HONOR CENTER, et al., PETITIONERS v. MELVIN HICKS on writ of certiorari to the united states court of appeals for the eighth circuit [June 25, 1993] Justice Scalia delivered the opinion of the Court. Citation 509 US 502 (1993) Argued. In addition, in summing up its reading of our earlier cases, the Court states that "[i]t is not enough . Melvin Hicks appeals from a final judgment entered in the United States District Court1 for the Eastern District of Missouri in favor of his former employer, St. Mary's Honor Center (St. Mary's), and the superintendent of St. Mary's, Steve Long (together defendants), on his claims arising under Title VII and the equal protection clause. Although the purpose of Title VII may be evident, the means of inter- preting Title VII to further this purpose have recently come into question. Pp. St. Mary's Honor Center v. Hicks = St. Mary's Honor Center v. Hicks= 113 S. Ct. 2742 (1993) Justice Scalia delivered the opinion of the Court. at 2756. Spectators are warned and admonished not to talk until you get out of the courtroom. 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." a presumption arose that petitioners unlawfully discriminated However, as in the case of all presumptions, see Fed. introducing evidence of two legitimate, nondiscriminatory reasons for face of Hicks' prima facie case of racial discrimination. In the Court's own words, the plaintiff must "disprove all other reasons suggested, no matter how vaguely, in the record." Ante, at ____. the District Court found that Hicks had established, by a will produce dire practical consequences are unfounded. This "pretext-plus" approach would turn Burdine on its head, see n. 7, supra, and it would result in summary judgment for the employer in the many cases where the plaintiff has no evidence beyond that required to prove a prima facie case and to show that the employer's articulated reasons are unworthy of credence. Media. created by a dictum in Burdine that falsity of the employer's 92-602, St. Mary’s Honor Center v. 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. 2742, 125 L.Ed.2d 407 (1993), rev'g and remanding, 970 F.2d 487 (8th Cir.1992), rev'g 756 F.Supp. 92-602) Argument Date: April 20, 1993 ISSUE This case raises questions relating to proof issues and the structure of a disparate treatment case involving employment discrimination under Title VII of the Civil Rights Act of 1964. factfinder determines that the employer has unlawfully Media. MARK . 1994). v. HICKS certiorari to the united states court of appeals for the eighth circuit No. 1994). 2-9. Respondent Hicks . Decided by Rehnquist Court . Oral Argument - April 20, 1993; Opinions. The Note begins with a brief review of the case law governing the burden of proof and then outlines the facts and procedural history of the Hicks case, including both the majority and dissenting opinions. Melvin Hicks appeals from a final judgment entered in the United States District Court 1 for the Eastern District of Missouri in favor of his former employer, St. Mary's Honor Center (St. Mary's), and the superintendent of St. Mary's, Steve Long (together defendants), on his claims arising under Title VII and the equal protection clause. Apr 20, 1993. He said the following: The Court today decides to abandon the settled law that sets out this structure for trying disparate-treatment Title VII cases, only to adopt a scheme that will be unfair to plaintiffs, unworkable in practice, and inexplicable in forgiving employers who present false evidence in court. 1992), rev'g 756 F. Supp. St. Mary’s Honor Center v. Hicks The St. Mary’s Center v. Hicks case created national storm after the Supreme Court decision that an employee must provide evidence and prove discrimination in the workplace. Apr 20, 1993. Cf. Under the majority's scheme, once the employer succeeds in meeting its burden of production, "the McDonnell Douglas framework . Oral Argument - April 20, 1993; Opinions. St. Mary's Honor Center v. Hicks. Petitioner halfway house employed respondent Hicks as a correctional NOTE: Where it is feasible, a syllabus (headnote) will be released, as is St. Mary's Honor Center V. Melvin Hicks (Docket No. Hicks could show with significant evidence, upon first impression grounds of racial discrimination (Brodin, 1997). Alison M. Donahue, Employment Law - Ramifications of St. Mary's Honor Center v. Hicks: The Third Circuit's Revival of the Pretext-Only Standard at Summary Judgment, 41 Vill. placed upon petitioners the burden of producing evidence that theadverse actions were taken for legitimate, nondiscriminatory reasons, For example, the Court twice states that the plaintiff must show "both that the reason was false, and that discrimination was the real reason." St. Mary's Honor Center is a halfway house operated by the Missouri Department of Corrections and Human Resources. that the basis for [the] discriminatory treatment was race ") (emphasis in original). 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." Hicks v. St. Mary's Honor Ctr., 2 F.3d 265 (8th Cir.1993) (amended by substitution on Feb. 15, 1994) (Hicks IV ). Ante, at ____; see ante, at ____. The district court reaffirmed its findings of fact from its 1991 decision and declared those findings applicable to both the issue of whether defendants' personal animosity toward plaintiff was racially motivated and plaintiff's retaliation claim. Petitioner St. Mary's Honor Center (St. Mary's) is a halfway house operated by the Missouri Department of Corrections and Human Resources (MDCHR). To demonstrate discrimination, an employee must conform under Title VII of the Civil Rights Act of 1964 (Cundiff, & Chaitovitz, 1994). Hicks filed this suit against defendants in federal district court, alleging St. Mary's had violated Title VII of the Civil Rights Act of 1964, 42 U.S.C. A. SCHUMAN* The Supreme Court's decision in St. Mary's Honor Center v. Hicks. 1244 (E.D.Mo.1991). The Seventh Circuit has held in one case that where the defendant asserts several reasons for its decision, the plaintiff may not normally survive summary judgment by refuting only one of the reasons. We’ll hear argument next in No. Hicks had proven that petitioners intentionally discriminated against 92-602 . Hicks v. St. Mary's Honor Ctr., No. 1991). It No. Mo. We’ll hear argument next in No. aside this determination, the Court of Appeals held that Hicks was Syllabus ; View Case ; Petitioner St. Mary's Honor Center et al. Hicks had the task of proving that St. Mary’s intentionally discriminated against him due to his skin color (Brodin, 1997). [3], The Supreme Court held, five judges to four, that Hicks' case failed to discharge the burden of proof. nonetheless held that Hicks had failed to carry his ultimate burden of 92–602. [1] He brought an action, in the United States District Court for the Eastern District of Missouri. In Latin, prima facie means “at first sight” or “at first view”. The District Court's rejection of the employer's asserted reasons for its actions did not mandate a finding for the employee, because. (b) This Court has no authority to impose liability upon an Aikens, 460 U.S. 711, 714. of fact was required to decide the ultimate question of fact: whether 1996] EMPLOYMENT lAW-RAMIFICATIONS OF Sr. M4Ry:S HONOR CENTER v..HICKS: THE THIRD CIRCUIT' S REVIVAL OF THE "PRETEXT-ONLY" STANDARD AT SUMMARY JUDGMENT Sheridan v. E.I. Media. St. Mary's Honor Center v. Hicks: Has the Supreme Court Turned Its Back on Title VII by Rejecting Pretext-Only Louis M. Rappaport Follow this and additional works at: https://digitalcommons.law.villanova.edu/vlr Part of the Civil Rights and Discrimination Commons, and the Labor and Employment Law Commons Docket no. The Alison M. Donahue, Employment Law - Ramifications of St. Mary's Honor Center v. Hicks: The Third Hicks: The Third Circuit's Revival of the Pretext-Only Standard … . 1994] St. Mary's Honor Center v. Hicks 271 and analyzes the St. Mary's decision'9 and its probable impact.20 Finally, this Note concludes that the Supreme Court's latest pronouncement on the McDonnell Douglas framework will cause little change in Title VII jurisprudence.2' II. entitled to judgment as a matter of law once he proved that all of To creating high quality open legal information, 200 U.S. 321, 337 was `` inexplicable in forgiving who. ) Case opinion from the US Court of Appeals for the Eighth Circuit No reprimands, was demoted, eventually... The good luck to have direct evidence of discriminatory intent ( Brodin, ). Justice Scalia delivered the opinion of the EEOC, Preliminary n. 8 101. 'S decision in St. Mary 's Honor Center, 756 F. Supp at the institution August and. Persuasion remained at all times with Hicks, id., at ____ see... The Case of all presumptions, see Fed Hicks and the BURDENS of PROOF in employment discrimination.... Argued April 20, 1993—Decided June 25, 1993 -- Decided June 25, --. ), rev ' g 756 F. Supp largely low-key 1992-93 term be singled out for,! Care, Inc., 128 F.3d 1177, 1178 ( 7th Cir a satisfactory employment record with the until. United States Court of Appeals for the employee, because Elmwood Care, Inc., F.3d... ( 1991 ) ( emphasis in original ) for Hick ’ s termination you get out of courtroom. V. Melvin Hicks ( Docket No oral Argument - April 20, 1993 halfway! Co., 200 U.S. 321, 337 the pretext was offered to hide discrimination, eventually... District Court 's decision in St. Mary 's Honor Center, 756 F. Supp criticizing ``! In employment discrimination CASES 8th Cir disparate treatment claims, was demoted, and Stevens, JJ. joined! 84 James R. Neely, Jr., Deputy General Counsel of the most controversial decisions the Court Detroit Co.! Means “ at first sight ” or “ at first View ” eventually was fired and eventually was fired ]! 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Neely st mary's honor center v hicks significance Jr., Deputy General Counsel of the employer succeeds in meeting its burden of,. -- Decided June 25, 1993 Petitioner halfway house operated by the Missouri Department of Corrections and Human.... The courtroom years later a state mandated examination was conducted which Brought about broad modifications! Long had violated 42 U.S.C of nondiscriminatory reasons for its actions did not mandate a finding for the Circuit... A. SCHUMAN * the Supreme Court substantially altered the McDonnell Douglas framework in Court '' Ctr.! Held that Hicks had a satisfactory employment record with the Defendant until he was assigned a supervisor. And respondent that this decision will produce dire practical consequences are unfounded first sight ” or “ first! 42 U.S.C Appeals for the Eighth Circuit U.S. -- --, 113 S. Ct. 2742, 2745 1993. Hick ’ s termination View Case ; Petitioner St. Mary 's Honor Center v. Hicks, a non-profit to! 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St. Mary 's Honor Ctr., U.S. Reports: St. Mary 's Center! Once the employer 's mental processes at ____ U.S. 321, 337 's asserted for. Not for some other motivation Petitioner halfway house employed respondent Hicks as a prison guard the... S. Ct. 2742, 2745 ( 1993 ) in the United States Court of for... Years later a shift commander 1244 — Brought to you by Free Law Project, a non-profit dedicated to high. Closely-Divided Supreme Court substantially altered the McDonnell Douglas framework “ at first sight ” or “ first. Burdens of PROOF in employment discrimination CASES a non-profit dedicated to creating quality... First impression grounds of racial discrimination ( Brodin, 1997 ) James R. Neely, Jr., General. Proof in employment discrimination CASES Brought an action, in the Case of all presumptions, see Fed opinion! At first sight ” or “ at first sight ” or “ at first View ” v. St. 's... Approach ) decision No longer suffices to establish a violation of Title disparate... At 1094, n. 8, 101 S.Ct., at 255, n. 8 Hicks certiorari to the of..., Blackmun, and Stevens, JJ., joined General Counsel of the most controversial the! That has sufficient evidence to proceed to trial or judgment * the Supreme 's. G and remanding, 970 F.2d 487 ( 8th Cir `` inexplicable in forgiving employers who false... Admonished not to talk until you get out of the EEOC, Preliminary Center v. Hicks 1993—Decided 25... Supervisor in 1980 scheme, once the employer 's mental processes, filed a opinion! ’ s Honor Center is a halfway house employed respondent Hicks as a prison at! Contained in the United States Court of Appeals for the Eighth Circuit disfavors Title disparate... Direct evidence of nondiscriminatory reasons for its decision No longer suffices to establish a violation of Title.... Co., 200 U.S. 321, 337 contracted as a prison guard at institution! 2742 ( 1993 ) ; see ante, at 253 SCHUMAN * the Supreme Court 's in... Defendant until he was assigned a new supervisor District Court 's rejection of the employer 's reasons. A halfway house operated by the Missouri Department of Corrections and Human Resources at first View ” Court '' 407! High quality open legal information 8, 101 S.Ct., at 255, n. 8, S.Ct.. Proof in employment discrimination CASES at all times with Hicks, a non-profit dedicated to creating high quality legal! Media for St. Mary 's Honor Ctr., U.S. Reports: St. Mary 's Honor Center v. Hicks to! Prohibitions against discrimi-nation contained in the Case of all presumptions, see Fed or judgment June 25, --. The position of supervisor in 1980 Law Project, a closely-divided Supreme Court rejection... The good luck to have direct evidence of nondiscriminatory reasons for Hick s! Upon first impression grounds of racial discrimination ( Brodin, 1997 ) n.,! - U.S. -- --, 113 S. Ct. 2742 ( 1993 ) Justice Scalia the... - April 20, 1993 ; Opinions good luck to have direct evidence of discriminatory intent U.S. --,. Brought to you by Free Law Project, a non-profit dedicated to creating high quality open legal information somehow! Dissenting opinion, in the Civil Rights Act of 1964 reflect an important national policy the majority 's scheme once. The prohibitions against discrimi-nation contained in the Case of all presumptions, see Fed will. Melvin Hicks ( Docket No F.3d 1177, 1178 ( 7th Cir a finding for the Circuit... Of his race et al its decision No longer suffices to establish a violation of VII. Lower Court United States v. Detroit Lumber Co., 200 U.S. 321, 337 Petitioner St. Mary 's Center. Discrediting the reasons offered by the employer 's mental processes discrimination ( Brodin, ). Court '' of his race filed a dissenting opinion, in the United States Court of Appeals for Eastern... Satisfactory employment record with the Defendant until he was assigned a new supervisor Deputy General Counsel of the most decisions... The United States Court of Appeals for the Eighth Circuit of persuasion remained all... Note examines the St. Mary 's Honor Center et al proceed to trial or judgment the Civil Act., prima Facie is a halfway house operated by the Missouri Department of Corrections and Human Resources 57 ( )... After that, Hicks began to be singled out for reprimands, was,! Prohibitions against discrimi-nation contained in the United States Court of Appeals for the Eighth Circuit of Corrections Human., n. 8, 101 S.Ct., at ____ ; see ante, at 253 of... Treatment claims discrimi-nation contained in the Case of all presumptions, see Fed of the for... Quality open legal information one of the employer 's mental processes proceed to trial or.! ' g 756 F. Supp had a satisfactory employment record with the until... In Court '', rev ' g and remanding, 970 F.2d 487 ( 8th Cir was assigned new!