reeves v sanderson plumbing products, inc

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. Roger Reeves, 57, and Joe Oswalt, in his mid-thirties, were supervisors in different Sanderson Plumbing Products, Inc. departments. 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. Oswalt explained that Chesnut "tolerated quite a bit" from him even though he "defied" Chesnut "quite often," but that Chesnut treated petitioner "[i]n a manner, as you would ... treat ... a child when ... you're angry with [him]." 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. 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). Petitioner testified that Chesnut had told him that he "was so old [he] must have come over on the Mayflower" and, on one occasion when petitioner was having difficulty starting a machine, that he "was too damn old to do [his] job." 3 id., at 72-73. 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. However, in agreeing to review the case, the Supreme Court considered … Oswalt, roughly 24 years younger than petitioner, corroborated that there was an "obvious difference" in how Chesnut treated them. 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. Sanderson Plumbing Products, Inc., involved allegations of age discrimination (see lead story in Spring 2000 Preventive Strategies). Id., at 519. 4 id., at 206. This burden is one of production, not persuasion; it "can involve no credibility assessment." 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 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. 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." 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. See 197 F. 3d, at 693. 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." See ibid. No. 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. 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. 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. Whether judgment as a matter of law is appropriate in any particular case will depend on a number of factors. 7, 3 Record 108-112. 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. 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 … Reeves’ … 3 id., at 80. 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." Based on this evidence, the Court of Appeals concluded that petitioner "very well may be correct" that "a reasonable jury could have found that [respondent's] explanation for its employment decision was pretextual." Firefox, or 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. … Id., at 694. 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. 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. 3 id., at 100, 142, 154; 4 id., at 191-192, 213. Cf. 3 Record 26. 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. Pp. Inc. (Sanderson) under the Age Discrimination in Employment Act (ADEA). 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. Argued March 21, 2000-Decided June 12,2000. 36, 38. 2 Record, Doc. 99–536. This Court need not--and could not--resolve all such circumstances here. Ibid. 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. Because the monthly attendance reports did not indicate a problem, Chesnut ordered an audit of the Hinge Room's timesheets for July, August, and September of that year. 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? 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." On closer examination, this conflict seems more semantic than real. Stay up-to-date with FindLaw's newsletter for legal professionals. If you do not cancel your Study Buddy subscription within the 14 day trial, your card will be charged for your subscription. Anderson v. Liberty Lobby, Inc., 477 U. S. 242, 250-251 (1986); see also Celotex Corp. v. Catrett, 477 U. S. 317, 323 (1986). 3 Record 20-22; 4 id., at 335. Microsoft Edge. 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. Your Study Buddy will automatically renew until cancelled. Thus, rejection of the defendant's proffered reasons will permit the trier of fact to infer the ultimate fact of intentional discrimination." 297-301 (2d ed. St. Mary's Honor Center, supra, at 509. Inc. (Sanderson) under the Age Discrimination in Employment Act (ADEA). 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™. Nos. See id., at 517. See 197 F. 3d, at 692. Chesnut testified that a 1993 audit of Hinge Room operations revealed "a very lax assembly line" where employees were not adhering to general work rules. Reeves presented evidence that his supervisor treated him adversely due to his age, and treated younger employees with patience and respect. 2 id., Doc. 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." 1. According to petitioner, Chesnut would regularly "cuss at me and shake his finger in my face." Your Study Buddy will automatically renew until cancelled. 4 id., at 267, 301. 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. Contributor Names O'Connor, Sandra Day (Judge) Supreme Court of the United States (Author) Created / Published 1999 … REEVES v. SANDERSON PLUMBING PRODUCTS, INC. certiorari to the united states court of appeals for the fifth circuit No. 3 id., at 6, 85-87; 4 id., at 335. Ibid. Cf. CO., United States Court of Appeals, … 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. 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. Reeves' duties included making sure workers under his supervision were … 100 F.3d 1061 - SHERIDAN v. E.I. 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. 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. 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). 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." The Fifth Circuit reversed. We must also decide whether the employer was entitled to judgment as a matter of law under the particular circumstances presented here. 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. In Reeves, the employer contended that the … Co., 997 F. 2d 1433, 1436 (CA11 1993); Boeing Co. v. Shipman, 411 F. 2d 365, 374 (CA5 1969) (en banc). During the trial, the District Court twice denied oral motions by respondent for judgment as a matter of law under Rule 50 of the Federal Rules of Civil Procedure, and the case went to the jury. See, e.g., Stokes v. Westinghouse Savannah River Co., 206 F. 3d 420, 429 (CA4 2000); Galabya v. New York City Bd. Petitioner, however, made a substantial showing that respondent's explanation was false. It therefore follows that, in entertaining a motion for judgment as a matter of law, the court should review all of the evidence in the record. 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. Pp. denied, 521 U. S. 1129 (1997); Gaworski v. ITT Commercial Finance Corp., 17 F. 3d 1104 (CA8) (same), cert. 16-19. 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. 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. Corp. v. Waters, 438 U. S. 567, 577. 197 F. 3d, at 691. 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… United States Supreme Court. 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. In so reasoning, the Court of Appeals misconceived the evidentiary burden borne by plaintiffs who attempt to prove intentional discrimination through indirect evidence. 197 F. 3d 688, 690 (CA5 1999). Exh. ; see also St. Mary's Honor Center, supra, at 507-508. 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. See App. Begin typing to search, use arrow keys to navigate, use enter to select. Fed. This is not to say that such a showing by the plaintiff will always be adequate to sustain a jury's finding of liability. The burden then shifts to the plaintiff to show that the employer’s true reason for the action was discriminatory. 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). 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. 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. An employee can prevail on a claim of employment discrimination even in the absence of direct proof that the employer acted with discriminatory intent. 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. 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. Reeves brought suit against Sanderson Plumbing Prods. O'Connor v. Consolidated Coin Caterers Corp., 517 U. S. 308, 311 (1996). 3 Record 38-40. Thus, 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. In June 1996, petitioner filed suit in the United States District Court for the Northern District of Mississippi, contending that he had been fired because of his age in violation of the Age Discrimination in Employment Act of 1967 (ADEA), 81 Stat. 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. 3 id., at 163-167; 4 id., at 225-226. Cf. The remaining question is whether, despite the Court of Appeals' misconception of petitioner's evidentiary burden, respondent was nonetheless entitled to judgment as a matter of law. Decided June 12, 2000. Ibid. 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." Because the parties do not dispute the issue, we shall assume, arguendo, that the McDonnell Douglas framework is fully applicable here. 3 id., at 23, 70; 4 id., at 335-336. 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. See id., at 693-694. ed. Further, Chesnut conceded that there had never been a union grievance or employee complaint arising from petitioner's recordkeeping, and that the company had never calculated the amount of overpayments allegedly attributable to petitioner's errors. 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." (emphasis added). 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. 1. Reeves appealed. The standard for judgment as a matter of law under Rule 50 mirrors the standard for summary judgment under Rule 56. Pp. William H. Rehnquist: We’ll hear argument next in 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." … 14-19. The judgment of the appellate court is reversed. Further, petitioner introduced evidence that Chesnut was the actual decisionmaker behind his firing. In October 1995, Sanderson followed the recommendation and discharged both petitioner and Caldwell. denied, 522 U. S. 1045 (1998); Sheridan v. E. I. DuPont de Nemours & Co., 100 F. 3d 1061 (CA3 1996) (same) (en banc), cert. Petitioner Roger Reeves worked for respondent Sanderson Plumbing Products, a manufacturer of toilet seats and covers, for 40 years. Argued March 21, 2000—Decided June 12, 2000 Petitioner Reeves, 57, and … Facts. 3 Record 183; 4 id., at 354. Furnco Constr. Petitioner worked in a department known as the "Hinge Room," where he supervised the "regular line." … St. Mary's Honor Center v. Hicks, 509 U. S. 502, 506 (1993). 3 id., at 20-21, 137-138. Ibid. 50(a); see also Weisgram v. Marley Co., 528 U. S. ___, ___ (2000) (slip op., at 5-7). 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. 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… Some decisions have stated that review is limited to that evidence favorable to the non-moving party, see, e.g., Aparicio v. Norfolk & Western R. Co., 84 F. 3d 803, 807 (CA6 1996); Simpson v. Skelly Oil Co., 371 F. 2d 563, 566 (CA8 1967), while most have held that review extends to the entire record, drawing all reasonable inferences in favor of the nonmovant, see, e.g., Tate v. Government Employees Ins. This much is evident from our decision in St. Mary's Honor Center. REEVES v. SANDERSON PLUMBING PRODUCTS, INC. You also agree to abide by our Terms of Use and our Privacy Policy, and you may cancel at any time. This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. See id., at 693-694. 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. 530 U.S. 133. 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. 99-536. 3 id., at 82. 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. 197 F. 3d, at 692-693. 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." 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. 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." 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. 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. 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). 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. Yes. I anticipate that such circumstances will be uncommon. Burdine, supra, at 256. videos, thousands of real exam questions, and much more. Ibid. Ibid. 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. Id., at 524. 14,000 + case briefs, hundreds of Law Professor developed 'quick' Black Letter Law. 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… If such conclusive demonstrations are (as I suspect) atypical, it follows that the ultimate question of liability ordinarily should not be taken from the jury once the plaintiff has introduced the two categories of evidence described above. 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.

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