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Landmark Supreme Court Cases: McDonnell Douglas Corp v. Green

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973), was an early ruling 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.

McDonnell Douglas was an aerospace company in St. Louis at the time of the lawsuit but has since been acquired by Boeing. Percy Green was a black mechanic and laboratory technician laid off by McDonnell Douglas in 1964 during a reduction in force at the company.

Green, a long-time activist in the civil rights movement, protested that his discharge was racially motivated. He and others used cars to block roads to McDonnell Douglas factories. On one occasion, someone used a chain to lock the front door of a McDonnell Douglas downtown business office, preventing employees from leaving, though it was not certain whether Green was responsible.

Soon after the locked-door incident, McDonnell Douglas advertised for vacant mechanic positions, for which Green was qualified. Green was not hired, McDonnell Douglas citing his participation in blocking traffic and chaining the building. Green subsequently filed a complaint with the EEOC, sued in U.S. District Court, and later appealed the decision to the U.S. Court of Appeals for the Eighth Circuit before the Supreme Court agreed to hear the case.

The McDonnell Douglas case established the order and framework that employment discrimination cases must follow:

  1. The plaintiff (employee) must first establish a prima facie case of discrimination which he can satisfy by showing that he belongs to a racial minority; he applied and was qualified for a job the employer was trying to fill; though qualified, he was rejected; and thereafter the employer continued to seek applicants with complainant's qualifications.
  2. The defendant (employer) must produce evidence of a legitimate non-discriminatory reason for its actions. If this occurs, then the presumption of discrimination dissipates.
  3. The plaintiff must then present facts to show an inference of discrimination. The plaintiff may do so either by showing that the defendant's explanation is insufficient and only a pretext for discrimination, or by otherwise proving that the defendant's actions used one of the listed unlawful discriminatory parameters.

The significance of this case is that it allows the plaintiff (employee) to shift the questions to be proved from whether the defendant has acted "because of" an unlawful discriminatory factor to whether the defendant has lied about the reasons it took action.

Since its issuance in 1973, all the federal courts have subsequently adopted the order and allocation of proof set out in McDonnell Douglas for all claims of disparate-treatment employment discrimination that are not based on direct evidence of discriminatory intent.

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