Petitioner Roger Reeves worked for respondent Sanderson Plumbing Products, a manufacturer of toilet seats and covers, for 40 years. Argued March 21, 2000. 3 id., at 23, 70; 4 id., at 335-336. In October 1995, petitioner Roger Reeves was 57 years old and had spent 40 years in the employ of respondent, Sanderson Plumbing Products, Inc., a manufacturer of toilet seats and covers. At trial, respondent contended that it had fired petitioner due to his failure to maintain accurate attendance records, while petitioner attempted to demonstrate that respondent's explanation was pretext for age discrimination. Again, the court disregarded critical evidence favorable to petitioner--namely, the evidence supporting petitioner's prima facie case and undermining respondent's nondiscriminatory explanation. I anticipate that such circumstances will be uncommon. Proof that the defendant's explanation is unworthy of credence is simply one form of circumstantial evidence that is probative of intentional discrimination, and it can be quite persuasive. 3 id., at 163-167; 4 id., at 225-226. 14,000 + case briefs, hundreds of Law Professor developed 'quick' Black Letter Law. Petitioner, however, made a substantial showing that respondent's explanation was false. denied, 504 U. S. 985 (1992); Ackerman v. Diamond Shamrock Corp., 670 F. 2d 66, 69 (CA6 1982). Whether a finding for intentional discrimination is sustainable if the fact finder has a reason to reject the employer’s nondiscriminatory reason for it’s decision and the plaintiff established a prima facie case for discrimination? 7, 3 Record 108-112. denied, 521 U. S. 1129 (1997); Gaworski v. ITT Commercial Finance Corp., 17 F. 3d 1104 (CA8) (same), cert. of Governors v. Aikens, 460 U. S. 711, 716 (1983), the Courts of Appeals, including the Fifth Circuit in this case, have employed some variant of the framework articulated in McDonnell Douglas to analyze ADEA claims that are based principally on circumstantial evidence. In St. Mary's Honor Center v. Hicks, 509 U. S. 502, 511, the Court stated that, because the factfinder's disbelief of the reasons put forward by the defendant, together with the elements of the prima facie case, may suffice to show intentional discrimination, rejection of the defendant's proffered reasons will permit the trier of fact to infer the ultimate fact of intentional discrimination. And the standard for granting summary judgment "mirrors" the standard for judgment as a matter of law, such that "the inquiry under each is the same." The District Court denied respondent's motions for judgment as a matter of law under Federal Rule of Civil Procedure 50, and the case went to the jury, which returned a verdict for Reeves. In 1995, Caldwell informed Powe Chesnut, the company's director of manufacturing, that Hinge Room production was down because employees were often absent, coming in late, and leaving early. See infra, at 15-16. A finding for intentional discrimination is sustainable if the fact finder has a reason to reject the employer’s nondiscriminatory reason for it’s decision and the plaintiff established a prima facie case for discrimination. The Fifth Circuit reversed. In this age discrimination case, Defendant-Appellant Sanderson Plumbing Products, Inc. ("Sanderson") appeals the district court's order denying Sanderson's post-verdict motion for judgment as a matter of … Id., at 694. 4 id., at 267, 301. The District Court denied respondent's motions and granted petitioner's, awarding him $28,490.80 in front pay for two years' lost income. REEVES v. SANDERSON PLUMBING PRODUCTS, INC. No. 509 U. S., at 511. 4 Record 204-205. 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. Moreover, once the employer's justification has been eliminated, discrimination may well be the most likely alternative explanation, especially since the employer is in the best position to put forth the actual reason for its decision. Petitioner testified that his job only included reviewing the daily and weekly attendance reports, and that disciplinary writeups were based on the monthly reports, which were reviewed by Caldwell. 3 id., at 20-21, 137-138. In holding that the record contained insufficient evidence to sustain the jury's verdict, the Court of Appeals misapplied the standard of review dictated by Rule 50. 21-24, 30-37; 4 Record 206-208. 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"). 3 id., at 26-27. Certainly there will be instances where, although the plaintiff has established a prima facie case and introduced sufficient evidence to reject the employer's explanation, no rational factfinder could conclude that discrimination had occurred. In this age discrimination case, Defendant-Appellant Sanderson Plumbing Products, Inc. ("Sanderson") appeals the district court's order denying Sanderson's post-verdict motion for judgment as a matter of … Petitioner Reeves… 3 Record 183; 4 id., at 354. 197 F.3d … 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. Respondent met this burden by offering admissible evidence sufficient for the trier of fact to conclude that petitioner was fired because of his failure to maintain accurate attendance records. 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). Moreover, once the employer's justification has been eliminated, discrimination may well be the most likely alternative explanation, especially since the employer is in the best position to put forth the actual reason for its decision. Ibid. The judgment of the appellate court is reversed. It suffices to say that, because a prima facie case and sufficient evidence to reject the employer's explanation may permit a finding of liability, the Court of Appeals erred in proceeding from the premise that a plaintiff must always introduce additional, independent evidence of discrimination. Thus, although the court should review the record as a whole, it must disregard all evidence favorable to the moving party that the jury is not required to believe. 1. It is undisputed that petitioner satisfied this burden here: (i) at the time he was fired, he was a member of the class protected by the ADEA ("individuals who are at least 40 years of age," 29 U. S. C. §631(a)), (ii) he was otherwise qualified for the position of Hinge Room supervisor, (iii) he was discharged by respondent, and (iv) respondent successively hired three persons in their thirties to fill petitioner's position. Furnco Constr. 530 U.S. 133. Sanderson Plumbing Products, Inc., involved allegations of age discrimination (see lead story in Spring 2000 Preventive Strategies). 3 id., at 90, 152. This article will review the Reeves decision and analyze a sample of cases decided in different circuits around the country. In this case, the evidence supporting respondent's explanation for petitioner's discharge consisted primarily of testimony by Chesnut and Sanderson and documentation of petitioner's alleged "shoddy record keeping." 14-19. The court explained, however, that this was "not dispositive" of the ultimate issue--namely, "whether Reeves presented sufficient evidence that his age motivated [respondent's] employment decision." 3 id., at 82. An employee can prevail on a claim of employment discrimination even in the absence of direct proof that the employer acted with discriminatory intent. Because the monthly attendance reports did not indicate a problem, Chesnut ordered an audit, which, according to his testimony, revealed numerous timekeeping errors and misrepresentations by Caldwell, Reeves, and Oswalt. Given the evidence in the record supporting petitioner, we see no reason to subject the parties to an additional round of litigation before the Court of Appeals rather than to resolve the matter here. See Furnco, 438 U. S., at 580 (evidence that employer's work force was racially balanced, while "not wholly irrelevant," was not "sufficient to conclusively demonstrate that [the employer's] actions were not discriminatorily motivated"). Specifically, the court noted that Chesnut's age-based comments "were not made in the direct context of Reeves's termination"; there was no allegation that the two other individuals who had recommended that petitioner be fired (Jester and Whitaker) were motivated by age; two of the decisionmakers involved in petitioner's discharge (Jester and Sanderson) were over the age of 50; all three of the Hinge Room supervisors were accused of inaccurate recordkeeping; and several of respondent's management positions were filled by persons over age 50 when petitioner was fired. See id., at 693-694. Moreover, the other evidence on which the court relied--that Caldwell and Oswalt were also cited for poor recordkeeping, and that respondent employed many managers over age 50--although relevant, is certainly not dispositive. 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. Thus, rejection of the defendant's proffered reasons will permit the trier of fact to infer the ultimate fact of intentional discrimination." That is, the plaintiff may attempt to establish that he was the victim of intentional discrimination "by showing that the employer's proffered explanation is unworthy of credence." Corp. v. Waters, 438 U. S. 567, 577 (1978) ("[W]hen all legitimate reasons for rejecting an applicant have been eliminated as possible reasons for the employer's actions, it is more likely than not the employer, who we generally assume acts with some reason, based his decision on an impermissible consideration"). Reeves v. Sanderson Plumbing Products, Inc. case brief Reeves v. Sanderson Plumbing Products, Inc. case brief. You also agree to abide by our. I write separately to note that it may be incumbent on the Court, in an appropriate case, to define more precisely the circumstances in which plaintiffs will be required to submit evidence beyond these two categories in order to survive a motion for judgment as a matter of law. Microsoft Edge. 3 id., at 17, 22. 4 id., at 206. See 197 F. 3d, at 693-694. And in attempting to satisfy this burden, the plaintiff--once the employer produces sufficient evidence to support a nondiscriminatory explanation for its decision--must be afforded the "opportunity to prove by a preponderance of the evidence that the legitimate reasons offered by the defendant were not its true reasons, but were a pretext for discrimination." Please check your email and confirm your registration. Ibid. This Court held in Reeves v. Sanderson Plumbing Prod-ucts, Inc., 530 U.S. 133 (2000), that a discrimination plaintiff survives a motion for judgment as a matter of law if he sub-mits (i) evidence supporting a prima facie case, as described in McDonnell Douglas Corp. v… Sanderson claimed to fire Reeves because of several timekeeping errors and misrepresentations of the department he oversaw; Reeves, however, provided evidence that his supervisor stated that Reeves was “so old he must have come over on the Mayflower” and the supervisor treated Reeves as if he was a child. Reeves brought suit against Sanderson Plumbing Prods. videos, thousands of real exam questions, and much more. 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. Id., at 694. Internet Explorer 11 is no longer supported. This burden is one of production, not persuasion; it "can involve no credibility assessment." Liberty Lobby, supra, at 255. Id., at 693-694. 197 F. 3d, at 692. In 1995, Chesnut ordered another investigation of the Hinge Room, which, according to his testimony, revealed that petitioner was not correctly recording the absences and hours of employees. Industrial Co. v. Zenith Radio Corp., 475 U. S. 574, 587, drawing all reasonable inferences in favor of the nonmoving party, but making no credibility determinations or weighing any evidence, e.g., Lytle v. Household Mfg., Inc., 494 U. S. 545, 554-555. Those include the strength of the plaintiff's prima facie case, the probative value of the proof that the employer's explanation is false, and any other evidence that supports the employer's case and that properly may be considered on a motion for judgment as a matter of law. 2 id., Doc. And in making this determination, the Court of Appeals ignored the evidence supporting petitioner's prima facie case and challenging respondent's explanation for its decision. Further, petitioner introduced evidence that Chesnut was the actual decisionmaker behind his firing. This is not to say that such a showing by the plaintiff will always be adequate to sustain a jury's finding of liability. According to Chesnut's testimony, that investigation revealed "numerous timekeeping errors and misrepresentations on the part of Caldwell, Reeves, and Oswalt." address. The court disregarded evidence favorable to Reeves--the evidence supporting his prima facie case and undermining respondent's nondiscriminatory explanation--and failed to draw all reasonable inferences in his favor. But both petitioner and Oswalt testified that the company's automated timeclock often failed to scan employees' timecards, so that the timesheets would not record any time of arrival. On these occasions, petitioner and Oswalt would visually check the workstations and record whether the employees were present at the start of the shift. Pl. 99–536. For instance, an employer would be entitled to judgment as a matter of law if the record conclusively revealed some other, nondiscriminatory reason for the employer's decision, or if the plaintiff created only a weak issue of fact as to whether the employer's reason was untrue and there was abundant and uncontroverted independent evidence that no discrimination had occurred. 99-536, Roger Reeves v. Sanderson Plumbing Products, Inc… Sanderson testified that she accepted the recommendation to discharge petitioner because he had "intentionally falsif[ied] company pay records." Although intermediate evidentiary burdens shift back and forth under this framework, "[t]he ultimate burden of persuading the trier of fact that the defendant intentionally discriminated against the plaintiff remains at all times with the plaintiff." Argued March 21, 2000—Decided June 12, 2000 Petitioner Reeves, 57, and … After noting respondent's proffered justification for petitioner's discharge, the court acknowledged that petitioner "very well may" have offered sufficient evidence for "a reasonable jury [to] have found that [respondent's] explanation for its employment decision was pretextual." 4 id., at 197-199, 237. Moreover, the other evidence on which the court relied--that Caldwell and Oswalt were also cited for poor recordkeeping, and that respondent employed many managers over age 50--although relevant, is certainly not dispositive. Ibid. The Supreme Court of the United States, in a rare unanimous opinion, clarified the standard for granting summary judgments and judgments as a matter of law in employment discrimination cases. Exh. 40, 41. Ibid. ; Texas Dept. On Reeves v.Sanderson Plumbing Products, Inc., 2000 WL743663 (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… Recognizing that "the question facing triers of fact in discrimination cases is both sensitive and difficult," and that "[t]here will seldom be `eyewitness' testimony as to the employer's mental processes," Postal Service Bd. Petitioner also demonstrated that, according to company records, he and Oswalt had nearly identical rates of productivity in 1993. 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. Decided June 12, 2000. Ibid. 3 Record 26. See 197 F. 3d, at 693. Whether the defendant was in fact motivated by discrimination is of course for the finder of fact to decide; that is the lesson of St. Mary's Honor Center v. Hicks, 509 U. S. 502 (1993). Addressing this question, the court weighed petitioner's additional evidence of discrimination against other circumstances surrounding his discharge. 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. See id., at 693-694. Chesnut and other company officials recommended to the company president, Sandra Sanderson, that Reeves and Caldwell be fired, and she complied. See 197 F. 3d, at 691-692. 3 id., at 118-123; 4 id., at 240-247, 283-285, 291, 293-294. The court instructed the jury that "[i]f the plaintiff fails to prove age was a determinative or motivating factor in the decision to terminate him, then your verdict shall be for the defendant." 3 id., at 100, 142, 154; 4 id., at 191-192, 213. In this case, in addition to establishing a prima facie case of discrimination and creating a jury issue as to the falsity of the employer's explanation, petitioner introduced additional evidence that Chesnut was motivated by age-based animus and was principally responsible for petitioner's firing. Id., at 691. 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. Justice O'Connor delivered the opinion of the Court. Because the Court's opinion leaves room for such further elaboration in an appropriate case, I join it in full. The court confined its review of evidence favoring petitioner to that evidenceshowing that Chesnut had directed derogatory, age-based comments at petitioner, and that Chesnut had singled out petitioner for harsher treatment than younger employees. Anderson v. Liberty Lobby, Inc., 477 U. S. 242, 255. Id., at 524. On closer examination, this conflict seems more semantic than real. 14-16. of Community Affairs v. Burdine, 450 U. S. 248, 252-253 (1981). O'Connor, J., delivered the opinion for a unanimous Court. CO., United States Court of Appeals, … A 1994 letter authored by Chesnut indicated that he berated other company directors, who were supposedly his co-equals, about how to do their jobs. AFFIRMING AMBIGUITY: REEVES V SANDERSON PLUMBING PROD UCTS, INC. AND THE BURDEN-SHIFTING FRAMEWORK OF DISPARATE TREATMENT CASES I. 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. DuPONT de NEMOURS AND CO., United States Court of Appeals, Third Circuit. Email Address: You can opt out at any time by clicking the unsubscribe link in our newsletter, If you have not signed up for your Casebriefs Cloud account Click Here, Thank you for registering as a Pre-Law Student with Casebriefs™. ROGER REEVES, PETITIONER v. SANDERSON PLUMBING PRODUCTS, INC. on writ of certiorari to the united states court of appeals for the fifth circuit. 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. 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. In reaching this conclusion, however, we reasoned that it is permissible for the trier of fact to infer the ultimate fact of discrimination from the falsity of the employer's explanation. The District Court plainly informed the jury that petitioner was required to show "by a preponderance of the evidence that his age was a determining and motivating factor in the decision of [respondent] to terminate him." The court instructed the jury that, to show that respondent's explanation was a pretext for discrimination, petitioner had to demonstrate "1, that the stated reasons were not the real reasons for [petitioner's] discharge; and 2, that age discrimination was the real reason for [petitioner's] discharge." Google Chrome, 3 Record 38-40. In Reeves, the employer contended that the … Petitioner similarly cast doubt on whether he was responsible for any failure to discipline late and absent employees. For these reasons, the judgment of the Court of Appeals is reversed. Fed. Thus, although the court should review the record as a whole, it must disregard all evidence favorable to the moving party that the jury is not required to believe. Reeves' duties included making sure workers under his supervision were on time and at work and logging such data. The Court of Appeals for the Fifth Circuit reversed, holding that petitioner had not introduced sufficient evidence to sustain the jury's finding of unlawful discrimination. You have successfully signed up to receive the Casebriefs newsletter. Oswalt, roughly 24 years younger than petitioner, corroborated that there was an "obvious difference" in how Chesnut treated them. 197 F. 3d, at 693. See Furnco, supra, at 580. Reeves v. Sanderson Plumbing Products, Inc., 530 U.S. 133 (2000), was a case before the United States Supreme Court concerning age discrimination in employment. In October 1995, petitioner Roger Reeves was 57 years old and had spent 40 years in the employ of respondent, Sanderson Plumbing Products, Inc., a manufacturer of toilet seats and covers. … Inc. (Sanderson) under the Age Discrimination in Employment Act (ADEA). Ginsburg, J., filed a concurring opinion. Respondent was not entitled to judgment as a matter of law under the particular circumstances presented here. This Court need not--and could not--resolve all such circumstances here. 5-14. Petitioner also testified that, on the day he was fired, Chesnut said that his discharge was due to his failure to report as absent one employee, Gina Mae Coley, on two days in September 1995. 1995) (hereinafter Wright & Miller). As a pre-law student you are automatically registered for the Casebriefs™ LSAT Prep Course. 29 U. S. C. §623(a)(1). 99-536. Contributor Names O'Connor, Sandra Day (Judge) Supreme Court of the United States (Author) Created / Published 1999 … Sanderson admitted that Caldwell, and not petitioner, was responsible for citing employees for violations of the company's attendance policy. Ibid. Moreover, Oswalt testified that all of respondent's employees feared Chesnut, and that Chesnut had exercised "absolute power" within the company for "[a]s long as [he] can remember." No. Moreover, although the presumption of discrimination "drops out of the picture" once the defendant meets its burden of production, St. Mary's Honor Center, supra, at 511, the trier of fact may still consider the evidence establishing the plaintiff's prima facie case "and inferences properly drawn therefrom ... on the issue of whether the defendant's explanation is pretextual," Burdine, supra, at 255, n. 10. The Courts of Appeals have articulated differing formulations as to what evidence a court is to consider in ruling on a Rule 50 motion. In Wilkerson, we stated that "in passing upon whether there is sufficient evidence to submit an issue to the jury we need look only to the evidence and reasonable inferences which tend to support the case of" the nonmoving party. In doing so, however, the court must draw all reasonable inferences in favor of the nonmoving party, and it may not make credibility determinations or weigh the evidence. REEVES v. SANDERSON PLUMBING PRODUCTS, INC. Unlock your Study Buddy for the 14 day, no risk, unlimited trial. 4 Record 197-199. Ibid. In other words, "[i]t is not enough ... to disbelieve the employer; the factfinder must believe the plaintiff's explanation of intentional discrimination." 99–536. The District Court was therefore correct to submit the case to the jury, and the Court of Appeals erred in overturning its verdict. Although Sanderson testified that she fired petitioner because he had "intentionally falsif[ied] company pay records," 3 id., at 100, respondent only introduced evidence concerning the inaccuracy of the records, not their falsification. REEVES v. SANDERSON PLUMBING PRODUCTS, INC. CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT No. Pp. (emphasis added). Cf. 99-536. denied, 522 U. S. 1045 (1998); Sheridan v. E. I. DuPont de Nemours & Co., 100 F. 3d 1061 (CA3 1996) (same) (en banc), cert. Facts. A plaintiff's prima facie case of discrimination (as defined in McDonnell Douglas Corp. v. Green, 411 U. S. 792, 802, and subsequent decisions), combined with sufficient evidence for a reasonable factfinder to reject the employer's nondiscriminatory explanation for its decision, may be adequate to sustain a finding of liability for intentional discrimination under the ADEA. See App. Lytle v. Household Mfg., Inc., 494 U. S. 545, 554-555 (1990); Liberty Lobby, Inc., supra, at 254; Continental Ore Co. v. Union Carbide & Carbon Corp., 370 U. S. 690, 696, n. 6 (1962). 36, 38. INTRODUCTION Title VII of the Civil … He stated that, although he and Chesnut "had [their] differences," "it was nothing compared to the way [Chesnut] treated Roger." Co., 950 F. 2d 816, 823 (CA1 1991), cert. Certainly there will be instances where, although the plaintiff has established a prima facie case and set forth sufficient evidence to reject the defendant's explanation, no rational factfinder could conclude that the action was discriminatory. 84 F.3d 803 - APARICIO v. NORFOLK & WESTERN RY. We must also decide whether the employer was entitled to judgment as a matter of law under the particular circumstances presented here. 100 F.3d 1061 - SHERIDAN v. E.I. Thus, the court must review all of the evidence in the record, cf., e.g., Matsushita Elec. Chesnut testified that this failure to discipline absent and late employees is "extremely important when you are dealing with a union" because uneven enforcement across departments would keep the company "in grievance and arbitration cases, which are costly, all the time." The defendant 's proffered reasons will permit the trier of fact to infer the question... The regular line, supervised by petitioner, was responsible for citing employees for of! Article will review the Reeves decision and analyze a sample of cases decided in different around! Could not -- resolve all such circumstances here Sept. 12, 1997 ) argument next in no falsif ied! Presented here v. Hicks, 509 U. S. 574, 587 ( 1986 ) reasons firing. 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