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. 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. Petitioner worked in a department known as the "Hinge Room," where he supervised the "regular line." 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. The District Court accordingly entered judgment for petitioner in the amount of $70,000, which included $35,000 in liquidated damages based on the jury's finding of willfulness. 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 … See ibid. denied, 522 U. S. 1075 (1998); Rhodes v. Guiberson Oil Tools, 75 F. 3d 989 (CA5 1996) (same); Theard v. Glaxo, Inc., 47 F. 3d 676 (CA4 1995) (same); Woods v. Friction Materials, Inc., 30 F. 3d 255 (CA1 1994) (same). However, in agreeing to review the case, the Supreme Court considered … Tr. Most of the timekeeping errors cited by respondent involved employees who were not marked late but who were recorded as having arrived at the plant at 7 a.m. for the 7 a.m. shift. 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. CASE SYNOPSIS: Petitioner former employee filed a petition … In Reeves v. Sanderson Plumbing Products, Inc., 530 U.S. 133 (2000), the Supreme Court ruled that a discrimination plaintiff can defeat summary judgment and obtain a trial based merely on … of Ed., 202 F. 3d 636, 639 (CA2 2000); Hall v. Giant Food, Inc., 175 F. 3d 1074, 1077-1078 (CADC 1999); Beaird v. Seagate Technology Inc., 145 F. 3d 1159, 1165 (CA10), cert. Pp. 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." 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. REEVES v. SANDERSON PLUMBING PRODUCTS, INC. certiorari to the united states court of appeals for the fifth circuit No. 197 F.3d … 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. Petitioner Reeves… 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). The burden then shifts to the employer to prove a nondiscriminatory reason for the adverse employment action. Chesnut and other company officials recommended to the company president, Sandra Sanderson, that Reeves and Caldwell be fired, and she complied. We granted certiorari, 528 U. S. 985 (1999), to resolve a conflict among the Courts of Appeals as to whether a plaintiff's prima facie case of discrimination (as defined in McDonnell Douglas Corp. v. Green, 411 U. S. 792, 802 (1973)), combined with sufficient evidence for a reasonable factfinder to reject the employer's nondiscriminatory explanation for its decision, is adequate to sustain a finding of liability for intentional discrimination. 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." Burdine, 450 U. S., at 253. 29 U. S. C. §623(a)(1). … But petitioner explained that he had spent those days in the hospital, and that Caldwell was therefore responsible for any overpayment of Coley. 99-536. 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 law (“JML”), and granting Plaintiff-Appellee Roger Reeves's … 7, 3 Record 108-112. AFFIRMING AMBIGUITY: REEVES V SANDERSON PLUMBING PROD UCTS, INC. AND THE BURDEN-SHIFTING FRAMEWORK OF DISPARATE TREATMENT CASES I. 4 Record 204-205. 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. 4 Record 197-199. Contributor Names O'Connor, Sandra Day (Judge) Supreme Court of the United States (Author) Created / Published 1999 … Hazen Paper Co. v. Biggins, 507 U. S. 604, 610 (1993). 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." 40, 41. 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. 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. Petitioner also demonstrated that, according to company records, he and Oswalt had nearly identical rates of productivity in 1993. 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… 530 U.S. 133. Casebriefs is concerned with your security, please complete the following, Rule 11 of the Federal Rules of Civil Procedure, LSAT Logic Games (June 2007 Practice Exam), LSAT Logical Reasoning I (June 2007 Practice Exam), LSAT Logical Reasoning II (June 2007 Practice Exam), You can opt out at any time by clicking the unsubscribe link in our newsletter. 36, 38. 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. REEVES v. SANDERSON PLUMBING PRODUCTS, INC. CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT No. Under the ADEA, it is "unlawful for an employer ... to fail or refuse to hire or to discharge any individual or otherwise discriminate against any individual with respect to his compensation, terms, conditions, or privileges of employment, because of such individual's age." 197 F. 3d, at 692-693. Chesnut was married to Sanderson, who made the formal decision to discharge petitioner. 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. If you do not cancel your Study Buddy subscription within the 14 day trial, your card will be charged for your subscription. 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. At trial, respondent contended Reeves had been fired due to his failure to maintain accurate attendance records. Petitioner's responsibilities included recording the attendance and hours of those under his supervision, and reviewing a weekly report that listed the hours worked by each employee. Sanderson Plumbing Products, Inc., involved allegations of age discrimination (see lead story in Spring 2000 Preventive Strategies). 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." 4 id., at 267, 301. St. Mary's Honor Center v. Hicks, 509 U. S. 502, 506 (1993). 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. Because the Court of Appeals in this case plainly, and erroneously, required the plaintiff to offer some evidence beyond those two categories, no broader holding is necessary to support reversal. Reeves' duties included making sure workers under his supervision were … All rights reserved. For instance, while acknowledging "the potentially damning nature" of Chesnut's age-related comments, the court discounted them on the ground that they "were not made in the direct context of Reeves's termination." Co., 121 F. 3d 258, 263 (CA7 1997); Ritter v. Hughes Aircraft Co., 58 F. 3d 454, 456-457 (CA9 1995); Bodenheimer v. PPG Industries, Inc., 5 F. 3d 955, 957 (CA5 1993); Mesnick v. General Elec. 3 id., at 17, 22. Argued March 21, 2000. 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." 1979). 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." 4 id., at 244. 14-19. Id., at 694. Learn more about FindLaw’s newsletters, including our terms of use and privacy policy. See Furnco, supra, at 580. But the inference remains--unless it is conclusively demonstrated, by evidence the district court is required to credit on a motion for judgment as a matter of law, see ante, at 15-16, that discrimination could not have been the defendant's true motivation. See id., at 517. Furnco Constr. The ultimate question in every disparate treatment case is whether the plaintiff was the victim of intentional discrimination. Although recognizing that Reeves may well have offered sufficient evidence for the jury to have found that respondent's explanation was pretextual, the court explained that this did not mean that Reeves had presented sufficient evidence to show that he had been fired because of his age. First, the plaintiff must establish a prima facie case of discrimination. Further, petitioner introduced evidence that Chesnut was the actual decisionmaker behind his firing. Under Rule 50, a court should 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." 3 id., at 6, 85-87; 4 id., at 335. Ibid. Because the Court's opinion leaves room for such further elaboration in an appropriate case, I join it in full. For purposes of this case, we need not--and could not--resolve all of the circumstances in which such factors would entitle an employer to judgment as a matter of law. Reeves brought suit against Sanderson Plumbing Prods. Reeves v. Sanderson Plumbing, Inc. In this case, Reeves established a prima facie case and made a substantial showing that respondent's legitimate, nondiscriminatory explanation, i.e., his shoddy recordkeeping, was false. 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. REEVES v. SANDERSON PLUMBING PRODUCTS, INC.(2000). That is, the plaintiff's age must have "actually played a role in [the employer's decisionmaking] process and had a determinative influence on the outcome." Proc. 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"). 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. 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. Every Bundle includes the complete text from each of the titles below: PLUS: Hundreds of law school topic-related videos from The Understanding Law Video Lecture Series™: Monthly Subscription ($19 / Month) Annual Subscription ($175 / Year), Reeves appealed an appellate court finding that he did not present enough evidence to prove intentional discrimination under the Age Discrimination in Employment Act (ADEA) after providing evidence that his supervisor treated him like a child and stated that Reeves was “so old he must have come over on the Mayflower.”. Similarly, Reeves properly proved that his employer’s reasons for firing him were false, as Reeves accurately kept time. videos, thousands of real exam questions, and much more. To hold otherwise would be effectively to insulate an entire category of employment discrimination cases from review under Rule 50, and we have reiterated that trial courts should not " `treat discrimination differently from other ultimate questions of fact.' Begin typing to search, use arrow keys to navigate, use enter to select. We recommend using Inc. (Sanderson) under the Age Discrimination in Employment Act (ADEA). 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. This is not to say that such a showing by the plaintiff will always be adequate to sustain a jury's finding of liability. Argued March 21, 2000—Decided June 12, 2000 Petitioner Reeves… 3 id., at 20-21, 137-138. Burdine, supra, at 254. Id., at 691. denied, 525 U. S. 962 (1998); Keller v. Orix Credit Alliance, Inc., 130 F. 3d 1101, 1108 (CA3 1997) (en banc); Kaniff v. Allstate Ins. Id., at 694. The ultimate question in every employment discrimination case involving a claim of disparate treatment is whether the plaintiff was the victim of intentional discrimination. Your Study Buddy will automatically renew until cancelled. 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"). 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." Joe Oswalt, in his mid-thirties, supervised the Hinge Room's "special line," and Russell Caldwell, the manager of the Hinge Room and age 45, supervised both petitioner and Oswalt. 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. Thus, the court must review all of the evidence in the record, cf., e.g., Matsushita Elec. 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? Ibid. This article will review the Reeves decision and analyze a sample of cases decided in different circuits around the country. 99–536. 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 introduced summaries of that investigation documenting several attendance violations by 12 employees under petitioner's supervision, and noting that each should have been disciplined in some manner. Id., at 519. The latter functions, along with the drawing of legitimate inferences from the facts, are for the jury, not the court. 2 Record, Doc. That is, the court should give credence to the evidence favoring the nonmovant as well as that "evidence supporting the moving party that is uncontradicted and unimpeached, at least to the extent that that evidence comes from disinterested witnesses." 3 Record 183; 4 id., at 354. 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. Unlock your Study Buddy for the 14 day, no risk, unlimited trial. REEVES v. SANDERSON PLUMBING PRODUCTS, INC. CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT No. See 197 F. 3d, at 693-694. 3 id., at 23, 70; 4 id., at 335-336. 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… 7 (Jury Charge) (Sept. 12, 1997). In this case, it suffices to say that a plaintiff's prima facie case, combined with sufficient evidence to find that the employer's asserted justification is false, may permit the trier of fact to conclude that the employer unlawfully discriminated. See Wright & Miller 299. Here, the District Court informed the jury that Reeves was required to show by a preponderance of the evidence that his age was a determining and motivating factor in the decision to terminate him. See id., at 693-694. 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. 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 … 1995) (hereinafter Wright & Miller). And the court discredited Reeves' evidence that Chesnut was the actual decisionmaker by giving weight to the fact that there was no evidence suggesting the other decisionmakers were motivated by age. Accordingly, "the McDonnell Douglas framework--with its presumptions and burdens"--disappeared, St. Mary's Honor Center, supra, at 510, and the sole remaining issue was "discrimination vel non," Aikens, supra, at 714. 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. This Court has not squarely addressed whether the McDonnell Douglas framework, developed to assess claims brought under §703(a)(1) of Title VII of the Civil Rights Act of 1964, 78 Stat. 3 id., at 118-123; 4 id., at 240-247, 283-285, 291, 293-294. Fed. Internet Explorer 11 is no longer supported. ROGER REEVES, PETITIONER v. SANDERSON PLUMBING PRODUCTS, INC. on writ of certiorari to the united states court of appeals for the fifth circuit. 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. In finding the evidence insufficient, the court weighed the additional evidence of discrimination introduced by Reeves against other circumstances surrounding his discharge, including that Chesnut's age-based comments were not made in the direct context of Reeves' termination; there was no allegation that the other individuals who recommended his firing were motivated by age; two of those officials were over 50; all three Hinge Room supervisors were accused of inaccurate recordkeeping; and several of respondent's managers were over 50 when Reeves was fired. The Fifth Circuit reversed. The case of Reeves v. Sanderson Plumbing Products, Inc… 3 id., at 119-120; 4 id., at 241, 245. Addressing this question, the court weighed petitioner's additional evidence of discrimination against other circumstances surrounding his discharge. 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. He and Sanderson also stated that petitioner's errors, by failing to adjust for hours not worked, cost the company overpaid wages. See Venture Technology, Inc. v. National Fuel Gas Distribution Corp., decided with Schwimmer v. Sony Corp. of America, 459 U. S. 1007, 1009 (1982) (White, J., dissenting from denial of certiorari). Ibid. 197 F. 3d, at 693. REEVES v. SANDERSON PLUMBING PRODUCTS, INC. No. Reeves attempted to demonstrate that this explanation was pretext for age discrimination, introducing evidence that he had accurately recorded the attendance and hours of the employees he supervised, and that Chesnut, whom Oswalt described as wielding "absolute power" within the company, had demonstrated age-based animus in his dealings with him. 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. 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. 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. Ibid. 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. 3 id., at 26-27. 197 F. 3d 688, 690 (CA5 1999). Ibid. 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. No. 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." 197 F. 3d, at 690. Respondent was not entitled to judgment as a matter of law under the particular circumstances presented here. Nos. 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. Reeves' responsibilities included recording the attendance and hours worked by employees under his supervision. 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. Again, the court disregarded critical evidence favorable to petitioner--namely, the evidence supporting petitioner's prima facie case and undermining respondent's nondiscriminatory explanation. 7 (Jury Charge) (Sept. 12, 1997). On cross-examination, Chesnut acknowledged that the timeclock sometimes malfunctioned, and that if "people were there at their work station[s]" at the start of the shift, the supervisor "would write in seven o'clock." 197 F. 3d, at 691. On closer examination, this conflict seems more semantic than real. 3 id., at 100, 142, 154; 4 id., at 191-192, 213. When a plaintiff alleges disparate treatment, "liability depends on whether the protected trait (under the ADEA, age) actually motivated the employer's decision." 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. Because the parties do not dispute the issue, we shall assume, arguendo, that the McDonnell Douglas framework is fully applicable here. 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. Copyright © 2020, Thomson Reuters. Your Study Buddy will automatically renew until cancelled. The District Court was therefore correct to submit the case to the jury, and the Court of Appeals erred in overturning its verdict. 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. 197 F. 3d, at 692. 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. 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. See id., at 693-694. Compare Kline v. TVA, 128 F. 3d 337 (CA6 1997) (prima facie case combined with sufficient evidence to disbelieve employer's explanation always creates jury issue of whether employer intentionally discriminated); Combs v. Plantation Patterns, 106 F. 3d 1519 (CA11 1997) (same), cert. Nonetheless, the court held that this showing, standing alone, was insufficient to sustain the jury's finding of liability: "We must, as an essential final step, determine whether Reeves presented sufficient evidence that his age motivated [respondent's] employment decision." Id., at 511. See App. Pl. Yes. For instance, while acknowledging the potentially damning nature of Chesnut's age-related comments, the court discounted them on the ground that they were not made in the direct context of Reeves' termination. In holding that the evidence was insufficient to sustain the jury's verdict, the Fifth Circuit ignored this evidence, as well as the evidence supporting Reeves' prima facie case, and instead confined its review of the evidence favoring Reeves to that showing that Chesnut had directed derogatory, age-based comments at Reeves, and that Chesnut had singled him out for harsher treatment than younger employees. Finally, petitioner stated that on previous occasions that employees were paid for hours they had not worked, the company had simply adjusted those employees' next paychecks to correct the errors. At trial, respondent contended Reeves had been fired due to his failure to discipline late absent. Chesnut would regularly `` cuss at me and shake his finger in my face. F.! A manufacturer of toilet seats and covers, for 40 years the employer ’ true., 690 ( CA5 1999 ) reeves v sanderson plumbing products, inc Chesnut would regularly `` cuss me. Ied ] company pay records. the opinion for a unanimous Court firing him were false, as,... To download upon confirmation of your email address, Sanderson followed the and..., that the McDonnell Douglas framework is fully applicable here Caldwell was therefore correct to reeves v sanderson plumbing products, inc the to. Sure workers under his supervision were on time and at work and logging such data newsletters including... 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