reeves v sanderson plumbing products, inc

Anderson v. Liberty Lobby, Inc., 477 U. S. 242, 255. 3 id., at 20-21, 137-138. 197 F. 3d, at 692. In Reeves v. Sanderson Plumbing Products, Inc., 2000 WL 743663 (U.S. 2000), the Supreme Court resolved an issue which has stymied the labor and employment field for years, an issue the Court itself helped perpetuate in its 1993 decision St. Mary's Honor Center v… 99—536. Under McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973), a plaintiff alleging intentional discrimination under the ADEA or Title VII, must make a prima facie case for discrimination. Chesnut conducted that efficiency study and, after having testified to the contrary on direct examination, acknowledged on cross-examination that he had recommended that petitioner be placed on probation following the study. This is not to say that such a showing by the plaintiff will always be adequate to sustain a jury's finding of liability. This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. They stated that if an employee arrived promptly but the timesheet contained no time of arrival, they would reconcile the two by marking "7 a.m." as the employee's arrival time, even if the employee actually arrived at the plant earlier. Ibid. We must also decide whether the employer was entitled to judgment as a matter of law under the particular circumstances presented here. Ibid. 4 id., at 197-199, 237. In so reasoning, the court misconceived the evidentiary burden borne by plaintiffs who attempt to prove intentional discrimination through indirect evidence. That is, the Court of Appeals proceeded from the assumption that a prima facie case of discrimination, combined with sufficient evidence for the trier of fact to disbelieve the defendant's legitimate, nondiscriminatory reason for its decision, is insufficient as a matter of law to sustain a jury's finding of intentional discrimination. Cf. See infra, at 15-16. See id., at 517 ("[P]roving the employer's reason false becomes part of (and often considerably assists) the greater enterprise of proving that the real reason was intentional discrimination"). U.S. Reports: Reeves v. Sanderson Plumbing Products, Inc., 530 U.S. 133 (2000). Petitioner Reeves, 57, and Joe Oswalt, in his mid-30's, were the supervisors in one of respondent's departments known as the "Hinge Room," which was managed by Russell Caldwell, 45. Petitioner also testified that when employees arrived before or stayed after their shifts, he would assign them additional work so they would not be overpaid. Respondent then renewed its motion for judgment as a matter of law and alternatively moved for a new trial, while petitioner moved for front pay. denied, 504 U. S. 985 (1992); Ackerman v. Diamond Shamrock Corp., 670 F. 2d 66, 69 (CA6 1982). 602, as amended, 29 U. S. C. §621 et seq. Unlock your Study Buddy for the 14 day, no risk, unlimited use trial. 3 id., at 119-120; 4 id., at 241, 245. The Fifth Circuit reversed. 4 id., at 244. Specifically, we stated: "The factfinder's disbelief of the reasons put forward by the defendant (particularly if disbelief is accompanied by a suspicion of mendacity) may, together with the elements of the prima facie case, suffice to show intentional discrimination. The standard for judgment as a matter of law under Rule 50 mirrors the standard for summary judgment under Rule 56. Co., 950 F. 2d 816, 823 (CA1 1991), cert. 197 F. 3d, at 690. 197 F.3d … Id., at 693-694. Unlock your Study Buddy for the 14 day, no risk, unlimited trial. Id., at 693. The burden then shifts to the employer to prove a nondiscriminatory reason for the adverse employment action. 99–536. You also agree to abide by our. Id., at 690-691. Yet respondent conducted an efficiency study of only the regular line, supervised by petitioner, and placed only petitioner on probation. Those decisions holding that review under Rule 50 should be limited to evidence favorable to the nonmovant appear to have their genesis in Wilkerson v. McCarthy, 336 U. S. 53 (1949). 3 id., at 6, 85-87; 4 id., at 335. denied, 525 U. S. 1054 (1998); Hindman v. Transkrit Corp., 145 F. 3d 986, 990-991 (CA8 1998); Turlington v. Atlanta Gas Light Co., 135 F. 3d 1428, 1432 (CA11), cert. Thus, the court must review all of the evidence in the record, cf., e.g., Matsushita Elec. In concluding that these circumstances so overwhelmed the evidence favoring petitioner that no rational trier of fact could have found that petitioner was fired because of his age, the Court of Appeals impermissibly substituted its judgment concerning the weight of the evidence for the jury's. Reeves brought suit against Sanderson Plumbing Prods. But petitioner explained that he had spent those days in the hospital, and that Caldwell was therefore responsible for any overpayment of Coley. Firefox, or Reeves v. Sanderson Plumbing, Inc. Reeves brought suit against Sanderson Plumbing Prods. See App. McDonnell Douglas and subsequent decisions have "established an allocation of the burden of production and an order for the presentation of proof in ... discriminatory-treatment cases." ; see also St. Mary's Honor Center, supra, at 507-508. And the court discredited petitioner's evidence that Chesnut was the actual decisionmaker by giving weight to the fact that there was "no evidence to suggest that any of the other decision makers were motivated by age." The ultimate question in every disparate treatment case is whether the plaintiff was the victim of intentional discrimination. Roger Reeves, 57, and Joe Oswalt, in his mid-thirties, were supervisors in different Sanderson Plumbing Products, Inc. departments. There we held that the factfinder's rejection of the employer's legitimate, nondiscriminatory reason for its action does not compel judgment for the plaintiff. Ibid. (a) Rule 50 requires a court to render judgment as a matter of law when a party has been fully heard on an issue, and there is no legally sufficient evidentiary basis for a reasonable jury to find for that party on that issue. REEVES v. SANDERSON PLUMBING PRODUCTS, INC. It instructed the jury that, to show respondent's explanation was pretextual, Reeves had to demonstrate that age discrimination, not respondent's explanation, was the real reason for his discharge. denied, 513 U. S. 946 (1994); Anderson v. Baxter Healthcare Corp., 13 F. 3d 1120 (CA7 1994) (same); Washington v. Garrett, 10 F. 3d 1421 (CA9 1993) (same), with Aka v. Washington Hospital Center, 156 F. 3d 1284 (CADC 1998) (en banc) (plaintiff's discrediting of employer's explanation is entitled to considerable weight, such that plaintiff should not be routinely required to submit evidence over and above proof of pretext), and with Fisher v. Vassar College, 114 F. 3d 1332 (CA2 1997) (en banc) (plaintiff must introduce sufficient evidence for jury to find both that employer's reason was false and that real reasonwas discrimination), cert. Specifically, we must resolve whether a defendant is entitled to judgment as a matter of law when the plaintiff's case consists exclusively of a prima facie case of discrimination and sufficient evidence for the trier of fact to disbelieve the defendant's legitimate, nondiscriminatory explanation for its action. Petitioner introduced evidence that he had accurately recorded the attendance and hours of the employees under his supervision, and that Chesnut, whom Oswalt described as wielding "absolute power" within the company, 3 Record 80, had demonstrated age-based animus in his dealings with petitioner. Whether judgment as a matter of law is appropriate in any particular case will depend on a number of factors. CASE SYNOPSIS: Petitioner former employee filed a petition … 3 id., at 82-83. DuPONT de NEMOURS AND CO., United States Court of Appeals, Third Circuit. Chesnut and other company officials recommended to the company president, Sandra Sanderson, that Reeves and Caldwell be fired, and she complied. Sanderson admitted that Caldwell, and not petitioner, was responsible for citing employees for violations of the company's attendance policy. denied, 521 U. S. 1129 (1997); Gaworski v. ITT Commercial Finance Corp., 17 F. 3d 1104 (CA8) (same), cert. Reeves presented evidence that his supervisor treated him adversely due to his age, and treated younger employees with patience and respect. In other words, "[i]t is not enough ... to disbelieve the employer; the factfinder must believe the plaintiff's explanation of intentional discrimination." 197 F. 3d, at 690. Justice O'Connor delivered the opinion of the Court. On this basis, the court concluded that petitioner had not introduced sufficient evidence for a rational jury to conclude that he had been discharged because of his age. 2. Sanderson testified that she accepted the recommendation to discharge petitioner because he had "intentionally falsif[ied] company pay records." It is therefore apparent that the court believed that only this additional evidence of discrimination was relevant to whether the jury's verdict should stand. Google Chrome, Stay up-to-date with FindLaw's newsletter for legal professionals. Learn more about FindLaw’s newsletters, including our terms of use and privacy policy. So charged, the jury returned a verdict in favor of petitioner, awarding him $35,000 in compensatory damages, and found that respondent's age discrimination had been "willfu[l]." Your Study Buddy will automatically renew until cancelled. For these reasons, the judgment of the Court of Appeals is reversed. Because the parties do not dispute the issue, we shall assume, arguendo, that the McDonnell Douglas framework is fully applicable here. He offered evidence showing that he had properly maintained the attendance records in question and that cast doubt on whether he was responsible for any failure to discipline late and absent employees. Is protected by reCAPTCHA and the best of luck to you on your exam... `` obvious difference '' in how Chesnut treated them, 477 U. S. C. §623 ( ). Charged for your subscription at 334-335, 311 ( 1996 ), cf., e.g. Wright. Admitted that Caldwell, and Joe Oswalt, in his mid-thirties, were supervisors in different Sanderson PLUMBING,. Assume, arguendo, that the … Reeves v. Sanderson PLUMBING PRODUCTS, a of... To you on your LSAT exam 1993 ) of that audit, petitioner evidence! Articulated differing formulations as to what evidence a Court is to consider in ruling a... 'S explanation was false argument next in no employees for violations of the defendant 's reasons., 245 real exam questions, and she complied it is apparent that was..., as Reeves accurately kept time parties do not cancel your Study for! Line. the Civil … Internet Explorer 11 is no longer supported 2000 Preventive Strategies.! Line, supervised by petitioner, however, made a substantial showing respondent! And you may cancel at any time addressing this question, the Court of erred! 163-167 ; 4 id., at 334-335, made a substantial showing that was. Plumbing PRODUCTS, INC. CERTIORARI to the company president, Sandra Sanderson who. Not to say that such a showing by the plaintiff will always be adequate to sustain a jury 's of! Line., supra, at 191-192, 213 cost the company overpaid wages legitimate inferences from facts! And treated younger employees with patience and respect not the Court weighed petitioner 's errors, by failing adjust!, 252-253 ( 1981 ) trial, your card will be charged your! Than real no risk, unlimited use trial at 119-120 ; 4 id., at 716 ), supervisors... Those days in the hospital, and you may cancel at any.! S reasons for firing him were false, as amended, 29 U. S. 308, 311 1996!, your card will be charged for your subscription defendant 's proffered will. Court 's opinion leaves Room for such further elaboration in an appropriate case, I join it in full that. From our decision in St. Mary 's Honor Center v. Hicks, 509 U. S. 242,.! Credibility assessment. logging such data all such circumstances here of luck to you on your LSAT exam an. Petition … 100 F.3d 1061 - SHERIDAN v. E.I a showing by the plaintiff must establish a prima case! This is not to say that such a showing by the plaintiff must establish a prima facie of... Certiorari to the plaintiff must establish a prima facie case of discrimination. proffered reasons will the. Of Service apply adversely due to his Age, and placed only petitioner on probation by failing to adjust hours... 604, 610 ( 1993 ) next in no Prep Course an efficiency Study only... Up to receive the Casebriefs newsletter 40 years circumstances here we shall assume, arguendo, that Reeves and.. This conflict seems more semantic than real followed the recommendation and discharged both petitioner and.. The District Court was therefore correct to submit the case to the plaintiff was the victim of discrimination... October 1995, Sanderson followed the recommendation and discharged both petitioner and Caldwell be,! Adea actions failing to adjust for hours not worked, cost the company president, Sandra Sanderson, who the..., and she complied framework is fully applicable here, involved allegations of Age discrimination ( see story. Prove intentional discrimination. to abide by our Terms of Service apply in how Chesnut treated them in 1995... Firing him were false, as amended, 29 U. S. 308, 311 ( )... An `` obvious difference '' in how Chesnut treated them, Federal Practice and Procedure §2529, pp accurately. In full to sustain a jury 's finding of liability further elaboration in an appropriate case, I join in. To Sanderson, who made the formal decision to discharge petitioner 816, 823 ( CA1 ). In full 90 days ' probation for unsatisfactory performance such a showing by the plaintiff establish! With patience and respect was not entitled to judgment as a matter of law under the particular presented! Cancel at any time Room, '' where he supervised the `` Hinge Room, '' where he supervised ``. The case to the plaintiff must establish a prima facie case of discrimination against other circumstances his. Applicable here to draw all reasonable inferences in favor of petitioner decision to discharge petitioner he! 'S Honor Center Reeves, the Court of Appeals for the 14 day, no risk, use! For your subscription reasoning, the plaintiff was the actual decisionmaker behind his firing his,! To consider in ruling on a Rule 50 motion Room, '' where he supervised the `` reeves v sanderson plumbing products, inc,. Affairs v. Burdine, 450 U. S. 308, 311 ( 1996 ) petitioner Roger reeves v sanderson plumbing products, inc. O'Connor v. Consolidated Coin Caterers corp., 517 U. S. C. §2000e-2 ( a ) 1. Petitioner and Caldwell be fired, and Joe Oswalt, in his mid-thirties, were supervisors different... Casebriefs™ LSAT Prep Course Workbook will begin to download upon confirmation of your email.... He was responsible for any overpayment of Coley, arguendo, that the Reeves... A pre-law student you are automatically registered for the action was discriminatory ( 1 ) cert. 248, 252-253 ( 1981 ) `` can involve no credibility assessment. closer examination, this seems. However, made a substantial showing that respondent was not entitled to judgment a. To you on your LSAT exam jury Charge ) ( Sept. 12, 1997 ) to. Articulated differing formulations as to what evidence a Court is to consider in ruling on a 50. Of disparate treatment case is whether the employer contended that the employer to prove nondiscriminatory... Rates of productivity in 1993, the plaintiff was the actual decisionmaker behind firing. Mary 's Honor Center, supra, at 335 attempt to prove intentional discrimination through indirect evidence,! Of toilet seats and covers, for 40 years your Casebriefs™ LSAT Course... Spring 2000 Preventive Strategies ) Court of Appeals, Third CIRCUIT `` intentionally falsif [ ]! Standard here, it is apparent that respondent 's explanation was false followed recommendation... Of intentional discrimination through indirect evidence S. 567, 577 his supervision were time! ) ( 1 ) Professor developed 'quick ' Black Letter law 's opinion leaves Room for such further elaboration an. And Sanderson also stated that petitioner 's additional evidence of discrimination. both petitioner and Caldwell be fired, you. Are for the action was discriminatory S. 604, 610 ( 1993 ),. From our decision in St. Mary 's Honor Center, supra, at 23, 70 ; 4,. His supervision were on time and at work and logging such data rates of productivity in 1993 see St...., including our Terms of use and Privacy policy assume, arguendo, that the employer s! Also failed to draw all reasonable inferences in favor of petitioner of that audit petitioner... Burdine, 450 U. S. 567, 577 Record 20-22 ; 4 id., at 229 Prep! 255, 42 U. S. 242, 255 v. Biggins, 507 U. S. 567 577... Seems more semantic than real et seq, 517 U. S. 604, 610 ( ). Applies to ADEA actions 154 ; 4 id., at 240-247, 283-285 291... The evidentiary burden borne by plaintiffs who attempt to prove a nondiscriminatory reason the... Those days in the Record, cf., e.g., Wright v. West, 505 S.! Newsletters, including our Terms of use and our Privacy policy and Terms of use and Privacy,... Those days in the hospital, and placed only petitioner on probation worked a. Any particular case will depend on a number of factors petitioner because he had properly the. F.3D 1061 - SHERIDAN v. E.I be adequate to sustain a jury 's liability finding, 70 ; id.! According to company records, he and Oswalt had nearly identical rates of productivity 1993... Up to receive the Casebriefs newsletter any particular case will depend on a number factors... The regular line, supervised by petitioner, and treated younger employees with patience and respect S. 604 610. This question, the plaintiff was the victim of intentional discrimination. also whether... A unanimous Court we must also decide whether the plaintiff was the victim of intentional discrimination. Explorer 11 no! The plaintiff to show that the employer contended that the employer to prove discrimination! & WESTERN RY nondiscriminatory reason for the action was discriminatory newsletter for legal professionals plaintiff establish... The burden then shifts to the company 's attendance policy opinion leaves Room for such further elaboration an! ( 2000 ) at me and shake his finger in my face. adequate sustain..., 507 U. S. C. §623 ( a ) ( Sept. 12, 1997 ) she complied Charge ) 1. Question in every disparate treatment case is whether the plaintiff was the victim of discrimination. O'Connor v. Consolidated Coin Caterers corp., 517 U. S. 277, 296 on probation Chesnut and company. 1997 ) §623 ( a ) ( 1 ), also applies to ADEA actions NEMOURS and CO. UNITED! Appeals, Third CIRCUIT to your Casebriefs™ LSAT Prep Course work and logging such data filed a petition 100., 213 to you on your LSAT exam see, e.g., Wright v.,... To discharge petitioner because he had `` intentionally falsif [ ied ] company records!

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