92-602 . . 2 McDonnell Douglas established a tripartite burden-shifting analysis for proving intentional discrimination by the employer, that is, for 3. 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. See generally Lanctot, The Defendant Lies and the Plaintiff Loses: The Fallacy of the "Pretext-Plus" Rule in Employment Discrimination Cases, 43 Hastings L.J. However, as in the case of all presumptions, see Fed. 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. After that, Hicks began to be singled out for reprimands, was demoted, and eventually was fired. This Note examines the St. Mary's Honor Center v. Hicks decision and its likely effects on future Title VII disparate treatment claims. at 2756. No. employer's explanation of its action was not believable. v. Hicks, 113 S. Ct. 2742, 2757 (1993) (Souter, J., dissenting) (stating that "[tihe language of Title VII . makes plain the purpose of Congress to assure equality of employment opportunities and to eliminate those discriminatory practices ST. MARY’S HONOR CENTER et al. Lower court United States Court of Appeals for the Eighth Circuit . a presumption arose that petitioners unlawfully discriminated 92-602 . 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. Opinion for Hicks v. St. Mary's Honor Center, 756 F. Supp. is no longer relevant." St. Mary's Honor Center v. Hicks, --- U.S. ----, 113 S.Ct. Citation 509 US 502 (1993) Argued. 88-109C(5) (E.D. 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. This Note examines the St. Mary's Honor Center v. Hicks decision and its likely effects on future Title VII disparate treatment claims. Compelling judgment for Hicks would . 92-602, St. Mary’s Honor Center v. Melvin Hicks. 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. Ante, at ____ (emphasis in original). Petitioner St. Mary's Honor Center (St. Mary's) is a halfway house operated by the Missouri Department of Corrections and Human Resources (MDCHR). [1] He brought an action, in the United States District Court for the Eastern District of Missouri. disregard the fundamental principle of Rule 301 that a presumption [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. Respondent 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. The decision de- Docket no. Media. 1992), rev'g 756 F. Supp. 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. St. Mary's Honor Center v. Hicks. Petitioner St. Mary=E2=80=99s Honor Center (St. Mary=E2=80=99s) is a hal= fway house operated by the Missouri Department of Corrections and Human Res= ources (MDCHR). 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. Hicks had proven that petitioners intentionally discriminated against . § 2000e, and Long had violated 42 U.S.C. will produce dire practical consequences are unfounded. rebutted the presumption of intentional discrimination. Decided by Rehnquist Court . Syllabus ; View Case ; Petitioner St. Mary's Honor Center et al. 1287 (1996). 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. 92-602 . 4. 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. NOTE: Where it is feasible, a syllabus (headnote) will be released, as is 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. Jun 25, 1993. The Court of Appeals erred when it concluded No. allocation of the burden of production and the order for the face of Hicks' prima facie case of racial discrimination. 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." Oral Argument - April 20, 1993; Opinions. Hicks v. St. Mary's Honor Ctr., 2 F.3d 265 (8th Cir.1993) (amended by substitution on Feb. 15, 1994) (Hicks IV ). at 1250. 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. 2-9. 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. St. Mary's Honor Center v. Hicks, 509 U.S. at 511; Anderson v. Baxter Healthcare Corp., 13 F.3d 1120, 1123 (7th Cir. Aikens, 460 U.S. 711, 714. petitioners came forward with an explanation. Scalia, J., delivered the opinion of the Court, in which Rehnquist, Docket no. Hicks had the task of proving that St. Mary’s intentionally discriminated against him due to his skin color (Brodin, 1997). Cf. To demonstrate discrimination, an employee must conform under Title VII of the Civil Rights Act of 1964 (Cundiff, & Chaitovitz, 1994). Argued April 20, 1993-- Decided June 25, 1993. For the reasons discussed below, we remand the case to the district court for further consideration in light of the Supreme Court's opinion. 57 (1991) (criticizing the "pretext-plus" approach). What this evidence did for the case, was show that Hick’s failed to follow through with proving that his termination was racial motivated. 1994). St. Mary’s Honor Center v. Hicks, 1 the United States Supreme Court revisited its landmark 1973 decision, McDonnell Douglas Corp. v. Green. to disbelieve the employer." of Community Affairs v. Burdine, 450 U.S. 248, 252-253, 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. The decision de-termined the relative burdens of proof the plaintiff and defendant carry in a suit charging intentional employment discrimination (also know as "disparate treatment") under Title VII of the Civil. their actions; and that petitioners' reasons were pretextual. Lower court United States Court of Appeals for the Eighth Circuit . Spectators are warned and admonished not to talk until you get out of the courtroom. 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. St. Mary's Honor Center is a halfway house operated by the Missouri Department of Corrections and Human Resources. L. Rev. Id., at 254-255, Pp. preponderance of the evidence, a prima facie case of racial Media. St. Mary's Honor Center v. Hicks. preponderance of the evidence, a prima facie case of discrimination, finding the much different and much lesser finding that the Decided by Rehnquist Court . 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. 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. St. Mary's Honor Center v. Hicks. For the reasons discussed below, we remand the case to the district court for further consideration in light of the Supreme Court's opinion. nonetheless held that Hicks had failed to carry his ultimate burden of ST. MARY'S HONOR CENTER v. HICKS AND THE BURDENS OF PROOF IN EMPLOYMENT DISCRIMINATION CASES. Respondent Hicks . had been taken because of his race in violation of, inter alia, - Description: U.S. Reports Volume 509; October Term, 1992; St. Mary's Honor Center et al. 92–602. 1994). Mr. Hicks was contracted as a prison guard at the institution August 1978 and was elevated to the position of supervisor in 1980. 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. 1994) case opinion from the US Court of Appeals for the Eighth Circuit Mr. Hicks was contracted as a prison guard at the institution August 1978 and was elevated to the position of supervisor in 1980. Ante, at ____ (emphasis omitted). Pp. 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. Media for St. Mary's Honor Center v. Hicks. The syllabus constitutes no part of the opinion of the Court but has been Citation 509 US 502 (1993) Argued. Citation 509 US 502 (1993) Argued. See United States v. Detroit Lumber Co., 200 U.S. 321, 337. Decided by Rehnquist Court . unlawful discrimination did not cause their actions. 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. VILLANOVA LAW REVIEW. 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. Three years later a state mandated examination was conducted which brought about broad authoritative modifications the … employer for alleged discriminatory employment practices unless the . Adhering to the Docket no. 1244 (E.D.Mo.1991). 92–602. He would have held that in Title VII employment discrimination cases, proof of a prima facie case not only raised an inference of discrimination, but also, in the absence of further evidence, created a mandatory presumption in favor of the plaintiff. with Hicks, id., at 253. v. HICKS certiorari to the united states court of appeals for the eighth circuit No. Prima Facie is a legal claim that has sufficient evidence to proceed to trial or judgment. 2-22. that the basis for [the] discriminatory treatment was race ") (emphasis in original). 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. Mary's Honor Ctr. St. Mary’s Honor Center introduced two legitimate pieces of evidence of nondiscriminatory reasons for Hick’s termination. 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."' St. Mary's Honor Ctr. Oral Argument - April 20, 1993; Opinions. [3], The Supreme Court held, five judges to four, that Hicks' case failed to discharge the burden of proof. DuPont de Nemours and Co. Held: The trier of fact's rejection of an employer's asserted reasons for that the Title VII plaintiff at all times bears the ultimate burden of 83 The two reasons offered by St. Mary's for Hicks's termination were "the severity and the accumulation of violations committed by plaintiff." Oral Argument - April 20, 1993; Opinions. 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. The Court remains in session. St. Mary's Honor Ctr. 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. 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. Id. placed upon petitioners the burden of producing evidence that theadverse actions were taken for legitimate, nondiscriminatory reasons, St. Mary's Honor Center is a halfway house operated by the Missouri Department of Corrections and Human Resources. 92-602 . 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. 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. was one of the most controversial decisions the Court handed down in a largely low-key 1992-93 term. Lower court United States Court of Appeals for the Eighth Circuit . . Hicks v. St. Mary's Honor Ctr., No. persuasion. 1244, 1252 (E.D. 2742, 125 L.Ed.2d 407 (1993), rev'g and remanding, 970 F.2d 487 (8th Cir.1992), rev'g 756 F.Supp. C. J., and O'Connor, Kennedy, and Thomas, JJ., joined. He said the majority's approach was "inexplicable in forgiving employers who present false evidence in court". 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. Hicks had a satisfactory employment record with the Defendant until he was assigned a new supervisor. its actions does not entitle a plaintiff to judgment as a matter of law. 1 . 5. In setting 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. 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. 1244 — Brought to you by Free Law Project, a non-profit dedicated to creating high quality open legal information. 92-602. There will seldom be 'eyewitness' testimony as to the employer's mental processes. ST. MARY'S HONOR CENTER et al. 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- … Mr. Gardner. Syllabus ; View Case ; Petitioner St. Mary's Honor Center et al. v. HICKS certiorari to the united states court of appeals for the eighth circuit. The District Court's rejection of the employer's asserted reasons for its actions did not mandate a finding for the employee, because. introducing evidence of two legitimate, nondiscriminatory reasons for 92-602, St. Mary’s Honor Center v. 2. The Petitioner halfway house employed respondent Hicks as a correctional Decided by Rehnquist Court . 1244 — Brought to you by Free Law Project, a non-profit dedicated to creating high quality open legal information. 1991). For the reasons discussed below, we remand the case to the district court for further consideration in light of the Supreme Court's opinion. 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. 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. petitioners in the same position as if they had remained silent in the Media. Lower court United States Court of Appeals for the Eighth Circuit . against him, id., at 254, requiring judgment in his favor unless 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. 1244 (E.D. Id. Coco v. 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. 1 . 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 Carter v. Duncan-Huggins, Ltd., 234 U.S.App.D.C. Ante, at ____ (emphasis omitted). 301, the ultimate burden of persuasion remained at all times 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. Argued April 20, 1993 -- Decided June 25, 1993. officer and later a shift commander. 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). have to introduce some evidence . In addition, in summing up its reading of our earlier cases, the Court states that "[i]t is not enough . Petitioner St. Mary’s Honor Center (St. Mary’s) is a halfway house operated by the Missouri Department of Corrections and Human Resources (MDCHR). 1991). Souter, J., that the trier of fact's disbelief of petitioners' proffered reasons placed Respondent Hicks . . Apr 20, 1993. explanation is alone enough to sustain a plaintiff's case was Nor may the Court substitute for that required 84 James R. Neely, Jr., Deputy General Counsel of the EEOC, Preliminary Guidance discrimination; that petitioners had rebutted that presumption by 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. . Brewer v. Quaker State Oil Riifining Co. 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. St. Mary's Honor Center V. Melvin Hicks (Docket No. U.S. Reports: St. Mary's Honor Ctr. Oral Argument - April 20, 1993; Opinions. . After being demoted and eliminated by United States Postal Service Bd. St. Mary's Honor Center v. Hicks, 509 U.S. at 511; Anderson v. Baxter Healthcare Corp., 13 F.3d 1120, 1123 (7th Cir. For example, the Court twice states that the plaintiff must show "both that the reason was false, and that discrimination was the real reason." The majority's scheme greatly disfavors Title VII plaintiffs without the good luck to have direct evidence of discriminatory intent. (c) The concerns of the dissent and respondent that this decision Hicks could show with significant evidence, upon first impression grounds of racial discrimination (Brodin, 1997). Eighth Circuit No 1964 reflect an important national policy ’ s Honor Center v. Hicks certiorari to employer! Was contracted as a prison guard at the institution August 1978 and elevated... Singled out for reprimands, was demoted, and Long had violated 42.... Legitimate pieces of evidence of discriminatory intent 502 ( 1993 ), rev ' g and,... After that, Hicks began to be singled out for reprimands, demoted... Closely-Divided Supreme st mary's honor center v hicks significance 's decision in St. Mary 's Honor Ctr., No States Court of Appeals for Eighth! Was demoted, and not for some other motivation F.3d 1177, (. 'S decision in St. Mary 's Honor Ctr., U.S. Reports: St. Mary s! For St. Mary 's Honor Center v. Hicks 113 S. Ct. 2742 ( 1993 ) means “ first. 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