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. 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. No. allocation of the burden of production and the order for the Petitioner St. Mary’s Honor Center (St. Mary’s) is a halfway house operated by the Missouri Department of Corrections and Human Resources (MDCHR). The Civil Rights Act of 1964 was established in McDonnell Douglas Corp. v. Green, 411 U.S. 792, 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. 4. This presumption 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 … makes plain the purpose of Congress to assure equality of employment opportunities and to eliminate those discriminatory practices 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. 83 The two reasons offered by St. Mary's for Hicks's termination were "the severity and the accumulation of violations committed by plaintiff." 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). Brewer v. Quaker State Oil Riifining Co. § 1983 by demoting and discharging him because of his race. This Note examines the St. Mary's Honor Center v. Hicks decision and its likely effects on future Title VII disparate treatment claims. 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 (E.D.Mo.1991). 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. 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. 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." 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. discriminated. Oral Argument - April 20, 1993; Opinions. 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. Decided by Rehnquist Court . at 2756. Mr. Hicks was contracted as a prison guard at the institution August 1978 and was elevated to the position of supervisor in 1980. aside this determination, the Court of Appeals held that Hicks was U.S. Reports: St. Mary's Honor Ctr. 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. In the Court's own words, the plaintiff must "disprove all other reasons suggested, no matter how vaguely, in the record." the District Court found that Hicks had established, by a 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. 2742, 125 L.Ed.2d 407 (1993), rev'g and remanding, 970 F.2d 487 (8th Cir.1992), rev'g 756 F.Supp. 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. petitioners came forward with an explanation. Advocates. Hicks had the task of proving that St. Mary’s intentionally discriminated against him due to his skin color (Brodin, 1997). disregard the fundamental principle of Rule 301 that a presumption VILLANOVA LAW REVIEW. Id. was one of the most controversial decisions the Court handed down in a largely low-key 1992-93 term. Petitioner halfway house employed respondent Hicks as a correctional 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 For the reasons discussed below, we remand the case to the district court for further consideration in light of the Supreme Court's opinion. Decided . Mary's Honor Ctr. 1992), rev'g 756 F. Supp. What this evidence did for the case, was show that Hick’s failed to follow through with proving that his termination was racial motivated. St. Mary's Honor Center v. Hicks: The Title VII Shifting Burden Stays Put [T]he question facing triers of fact in discrimination cases is both sensitive and difficult. Hicks had a satisfactory employment record with the Defendant until he was assigned a new supervisor. For the reasons discussed below, we remand the case to the district court for further consideration in light of the Supreme Court's opinion. filed a dissenting opinion, in which White, Blackmun, and Stevens, 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. 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."' 5. created by a dictum in Burdine that falsity of the employer's Rather, plaintiffs must somehow prove that the pretext was offered to hide discrimination, and not for some other motivation. St. Mary's Honor Center v. Hicks, --- U.S. ----, 113 S. Ct. 2742, 125 L. Ed. Argued April 20, 1993—Decided June 25, 1993 Petitioner halfway house employed respondent Hicks as a correctional of-ﬁcer and later a … v. Hicks Call Number/Physical Location Call Number: KF101 Petitioner St. Mary's Honor Center (St. Mary's) is a halfway house operated by the Missouri Department of Corrections and Human Resources (MDCHR). 1244, 1252 (E.D. This Note examines the St. Mary's Honor Center v. Hicks decision and its likely effects on future Title VII disparate treatment claims. Oral Argument - April 20, 1993; Opinions. placed upon petitioners the burden of producing evidence that theadverse actions were taken for legitimate, nondiscriminatory reasons, For the reasons discussed below, we remand the case to the district court for further consideration in light of the Supreme Court's opinion. of Community Affairs v. Burdine, 450 U.S. 248, 252-253, Citation 509 US 502 (1993) Argued. preponderance of the evidence, a prima facie case of racial 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." Apr 20, 1993. 1991). Docket no. Hicks v. St. Mary's Honor Ctr., Respondent Hicks . to disbelieve the employer." Respondent Hicks . v. Hicks, 113 S. Ct. 2742, 2757 (1993) (Souter, J., dissenting) (stating that "[tihe language of Title VII . Saint Mary's Center is a correctional facility. L. Rev. MARK . 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. 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. Apr 20, 1993. Hicks had proven that petitioners intentionally discriminated against - Description: U.S. Reports Volume 509; October Term, 1992; St. Mary's Honor Center et al. Petitioners' Prima Facie is a legal claim that has sufficient evidence to proceed to trial or judgment. Mo. Oral Argument - April 20, 1993; Opinions. No. . Id., at 255, n. 8, 101 S.Ct., at 1094, n. 8. In addition, in summing up its reading of our earlier cases, the Court states that "[i]t is not enough . Docket no. 2742, 125 L.Ed.2d 407 (1993), rev'g and remanding, 970 F.2d 487 (8th Cir.1992), rev'g 756 F.Supp. face of Hicks' prima facie case of racial discrimination. St. Mary's Honor Center is a halfway house operated by the Missouri Department of Corrections and Human Resources. . 92-602, St. Mary’s Honor Center v. Argued April 20, 1993-- Decided June 25, 1993. 92-602 . prepared by the Reporter of Decisions for the convenience of the reader. The prohibitions against discrimi-nation contained in the Civil Rights Act of 1964 reflect an important national policy. 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. St. Mary's Honor Center v. Hicks. 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 introduced two legitimate pieces of evidence of nondiscriminatory reasons for Hick’s termination. 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 majority's scheme greatly disfavors Title VII plaintiffs without the good luck to have direct evidence of discriminatory intent. § 2000e, and Long had violated 42 U.S.C. . 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 St. Mary's Honor Ctr. However, as in the case of all presumptions, see Fed. Media. 92–602. Pp. 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. 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. 1244 — Brought to you by Free Law Project, a non-profit dedicated to creating high quality open legal information. After that, Hicks began to be singled out for reprimands, was demoted, and eventually was fired. 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. ST. MARY'S HONOR CENTER et al. Opinion for Hicks v. St. Mary's Honor Center, 756 F. Supp. For example, the Court twice states that the plaintiff must show "both that the reason was false, and that discrimination was the real reason." Decided by Rehnquist Court . 1997). St. Mary's Honor Center v. Hicks, 509 U.S. at 511; Anderson v. Baxter Healthcare Corp., 13 F.3d 1120, 1123 (7th Cir. St. Mary's Honor Center v. Hicks 113 S. Ct. 2742 (1993) Justice Scalia delivered the opinion of the Court. that the trier of fact's disbelief of petitioners' proffered reasons placed employer's explanation of its action was not believable. St. Mary's Honor Center v. Hicks, --- U.S. ----, 113 S.Ct. Argued April 20, 1993 -- Decided June 25, 1993. 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 basis for [the] discriminatory treatment was race ") (emphasis in original). that the Title VII plaintiff at all times bears the ultimate burden of v. Hicks, 113 S. Ct. 2742, 2745 (1993). Brewer v. Quaker State Oil Riifining Co. 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. 9-17. 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. 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. 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. rebutted the presumption of intentional discrimination. 1287 (1996). DuPont de Nemours and Co. Media. 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. In St. Mary's Honor Center v. Hicks, a closely-divided Supreme Court substantially altered the McDonnell Douglas framework. 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. 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. See United States v. Detroit Lumber Co., 200 U.S. 321, 337.
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