The U.S. Supreme Court made it easier last week for workers to win employment-discrimination lawsuits by ruling that they usually will not need additional, independent evidence of bias when their employers’ stated reason for an adverse job action is shown to be false.
Many lower federal courts had required further evidence of actual discrimination even when plaintiffs had proved their employers’ explanations for dismissals or other job actions to be pretexts. But in its unanimous June 12 ruling in Reeves v. Sanderson Plumbing Products Inc. (Case No. 99-536), the Supreme Court rejected the evidentiary standard known as “pretext plus.”
While the case involved the federal Age Discrimination in Employment Act of 1967, legal experts said the court’s ruling would also apply to race- and sex-discrimination lawsuits filed under Title VII of the Civil Rights Act of 1964, as well as to job-bias cases brought under the Americans with Disabilities Act.
As large employers, school districts are sued often under those federal laws, particularly under Title VII.
Performance Questioned
The ruling came in the case of Roger Reeves, a supervisor for a plumbing-supplies manufacturer who was 57 years old in 1995 when he was dismissed and replaced by a younger worker. He sued under the age- discrimination law, arguing that the company’s stated reason for his dismissal— that he kept inaccurate attendance records—was a pretext for age bias.
After introducing evidence that he had kept accurate records and that some of his superiors had made age-based remarks about him, a jury awarded Mr. Reeves nearly $100,000 in damages. But the U.S. Court of Appeals for the 5th Circuit, in New Orleans, overturned the award and ruled that the company was entitled to win because Mr. Reeves had not introduced enough evidence that his dismissal was related to age bias.
In her opinion for the high court, Justice Sandra Day O’Connor said that once a plaintiff whose case meets basic discrimination criteria proves that his employer lied about its reasons for terminating him, he is entitled to win without having to come up with specific evidence that the employer discriminated against him.
“In appropriate circumstances, the trier of fact can reasonably infer from the falsity of the explanation that the employer is dissembling to cover up a discriminatory purpose,” Justice O’Connor said.
