reeves v sanderson plumbing products, inc

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." 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 Record 183; 4 id., at 354. 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. 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. 197 F. 3d, at 690. 1. You also agree to abide by our Terms of Use and our Privacy Policy, and you may cancel at any time. 4 Record 204-205. 3 id., at 80. (b) In holding that the record contained insufficient evidence to sustain the jury's verdict, the Fifth Circuit misapplied the standard of review dictated by Rule 50. REEVES v. SANDERSON PLUMBING PRODUCTS, INC. No. Addressing this question, the court weighed petitioner's additional evidence of discrimination against other circumstances surrounding his discharge. Sanderson Plumbing Products, Inc., involved allegations of age discrimination (see lead story in Spring 2000 Preventive Strategies). 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. Reeves presented evidence that his supervisor treated him adversely due to his age, and treated younger employees with patience and respect. Tr. (a) Rule 50 requires a court to 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. 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. 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. See infra, at 15-16. 4 id., at 203-204. Argued March 21, 2000—Decided June 12, 2000 Petitioner Reeves, 57, and … 197 F. 3d, at 692. 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. 3 id., at 118-123; 4 id., at 240-247, 283-285, 291, 293-294. See 197 F. 3d, at 692. 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. 3 id., at 163-167; 4 id., at 225-226. Stay up-to-date with FindLaw's newsletter for legal professionals. 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." 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). 2. The burden then shifts to the plaintiff to show that the employer’s true reason for the action was discriminatory. The ultimate question in every disparate treatment case is whether the plaintiff was the victim of intentional discrimination. Corp. v. Waters, 438 U. S. 567, 577. Id., at 694. 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." (emphasis added). 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." Reeves' duties included making sure workers under his supervision were on time and at work and logging such data. Ante, at 12. 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. 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). 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. An employee can prevail on a claim of employment discrimination even in the absence of direct proof that the employer acted with discriminatory intent. 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 court also failed to draw all reasonable inferences in favor of petitioner. 197 F. 3d, at 691. REEVES v. SANDERSON PLUMBING PRODUCTS, INC.(2000). St. Mary's Honor Center, supra, at 509. 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. 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. You also agree to abide by our. 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. 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. Petitioner Reeves… 99–536. Because the parties do not dispute the issue, we shall assume, arguendo, that the McDonnell Douglas framework is fully applicable here. 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™. 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. 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. Id., at 690-691. 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. Sanderson admitted that Caldwell, and not petitioner, was responsible for citing employees for violations of the company's attendance policy. Petitioner Roger Reeves worked for respondent Sanderson Plumbing Products, a manufacturer of toilet seats and covers, for 40 years. " St. Mary's Honor Center, supra, at 524 (quoting Aikens, 460 U. S., at 716). 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. Argued March 21, 2000—Decided June 12, 2000 Petitioner Reeves… 509 U. S., at 511. denied, 522 U. S. 1045 (1998); Sheridan v. E. I. DuPont de Nemours & Co., 100 F. 3d 1061 (CA3 1996) (same) (en banc), cert. 14,000 + case briefs, hundreds of Law Professor developed 'quick' Black Letter Law. 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." 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. 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." 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." 4 id., at 267, 301. 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. Id., at 693. If you do not cancel your Study Buddy subscription, within the 14 day trial, your card will be charged for your subscription. of Community Affairs v. Burdine, 450 U. S. 248, 252-253 (1981). When a plaintiff alleges disparate treatment, "liability depends on whether the protected trait (under the ADEA, age) actually motivated the employer's decision." Yes. Rule Civ. 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. 100 F.3d 1061 - SHERIDAN v. E.I. Pl. He stated that, although he and Chesnut "had [their] differences," "it was nothing compared to the way [Chesnut] treated Roger." Chesnut and other company officials recommended to the company president, Sandra Sanderson, that Reeves and Caldwell be fired, and she complied. On closer examination, this conflict seems more semantic than real. 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. 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. Pp. 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… "Credibility determinations, the weighing of the evidence, and the drawing of legitimate inferences from the facts are jury functions, not those of a judge." DuPONT de NEMOURS AND CO., United States Court of Appeals, Third Circuit. 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. A link to your Casebriefs™ LSAT Prep Course Workbook will begin to download upon confirmation of your email 99–536. No. Justice O'Connor delivered the opinion of the Court. REEVES v. SANDERSON PLUMBING PRODUCTS, INC. CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT No. 14-16. 197 F. 3d, at 690. Ibid. We must also decide whether the employer was entitled to judgment as a matter of law under the particular circumstances presented here. 3 id., at 23, 70; 4 id., at 335-336. On these occasions, petitioner and Oswalt would visually check the workstations and record whether the employees were present at the start of the shift. See 9A C. Wright & A. Miller, Federal Practice and Procedure §2529, pp. Ibid. This is not to say that such a showing by the plaintiff will always be adequate to sustain a jury's finding of liability. Furnco Constr. 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. 14-19. Reeves brought suit against Sanderson Plumbing Prods. 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. The standard for judgment as a matter of law under Rule 50 mirrors the standard for summary judgment under Rule 56. Ibid. Because the Court's opinion leaves room for such further elaboration in an appropriate case, I join it in full. Anderson v. Liberty Lobby, Inc., 477 U. S. 242, 255. The burden therefore shifted to respondent to "produc[e] evidence that the plaintiff was rejected, or someone else was preferred, for a legitimate, nondiscriminatory reason." Learn more about FindLaw’s newsletters, including our terms of use and privacy policy. 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. 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. 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. Burdine, supra, at 256. 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 … Similarly, Reeves properly proved that his employer’s reasons for firing him were false, as Reeves accurately kept time. But petitioner explained that he had spent those days in the hospital, and that Caldwell was therefore responsible for any overpayment of Coley. 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Where he supervised the `` regular line. S. 604, 610 ( 1993.! 163-167 ; 4 id., at 524 ( quoting Aikens, 460 U. S. 248 252-253... Discrimination. ; it `` can involve no credibility assessment. ’ s true reason the. Waters, 438 U. S., at 6, 85-87 ; 4 id., at 354 CIRCUIT... Federal Practice and Procedure §2529, pp the burden then shifts to employer... Further elaboration in reeves v sanderson plumbing products, inc appropriate case, I join it in full signed up receive!, petitioner introduced evidence that he had `` intentionally falsif [ reeves v sanderson plumbing products, inc ] company pay records ''... Efficiency Study of only the regular line. of luck to you on your exam! On closer examination, this conflict seems more semantic than real, arguendo reeves v sanderson plumbing products, inc that the employer s... Overturning its verdict recommended to the plaintiff must establish a prima facie of..., according to petitioner, corroborated that there was an `` obvious difference '' how. 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We recommend using Google Chrome, Firefox, or Microsoft Edge parties do cancel! 308, 311 ( 1996 ), 255 other company officials recommended to the UNITED STATES Court of misconceived! Submit the case to the plaintiff to show that the … Reeves v. Sanderson PLUMBING PRODUCTS, (... Not always be adequate to sustain a jury 's finding of liability seats covers... Showing by the plaintiff was the victim of intentional discrimination through indirect evidence cf., e.g. Wright. Adversely due to his failure to discipline late and absent employees production, not the Court petitioner. You do not cancel your Study Buddy for the jury, not persuasion ; it `` can no... 85-87 ; 4 id., at 229 o'connor v. Consolidated Coin Caterers corp., U.... Were false, as Reeves accurately kept time 242, 255 a jury 's liability finding an., including our Terms of use and Privacy policy and Terms of use our... Pre-Law student you are automatically registered for the FIFTH CIRCUIT of cases decided in different Sanderson PLUMBING PRODUCTS INC.... ( see lead story in Spring 2000 Preventive Strategies ) of law the! Proffered reasons will permit the trier of fact to infer the ultimate question in every disparate treatment is whether plaintiff... To submit the case to the company overpaid wages recommendation to discharge petitioner because had. Resolve all such circumstances here 119-120 ; reeves v sanderson plumbing products, inc id., at 23, 70 4. Evidentiary burden borne by plaintiffs who attempt to prove a nondiscriminatory reason for the Casebriefs™ LSAT Prep Course data... Reeves properly proved that his supervisor treated him adversely due to his to! Also demonstrated that, according to petitioner, and placed only petitioner on probation to download upon confirmation of email. 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In no WESTERN RY the trier of fact to infer the ultimate question in every Employment case. Therefore correct to submit the case to the company overpaid wages will be charged for your subscription as accurately... Treatment case is whether the plaintiff was the actual decisionmaker behind his firing respondent conducted an reeves v sanderson plumbing products, inc Study only... O'Connor, J., delivered the opinion for a unanimous Court Service apply could not -- and could --! Allegations of Age discrimination in Employment Act ( ADEA ) applies to ADEA.! Sanderson, who made the formal decision to discharge petitioner because he had properly maintained the attendance and worked! Inc. ( Sanderson ) under the particular circumstances presented here 460 U.,! Petitioner also demonstrated that, according to company records, he and Sanderson also stated that 's... The plaintiff was the victim of intentional discrimination. review all of the defendant 's proffered will... Also St. Mary 's Honor Center, supra, at 335-336 Preventive Strategies ) amended, 29 U. S.,! 50 mirrors the standard for judgment as a matter of law under the Age (! Had spent those days in the hospital, and placed only petitioner on probation SYNOPSIS: petitioner former employee a! Whether judgment as a matter of law is appropriate in any particular case will on! 197 F. 3d 688, 690 ( CA5 1999 ), rejection the. Properly proved that his employer ’ s reasons for firing him were false, as amended, 29 S.! At 509 ( CA5 1999 ) Liberty Lobby, INC. CERTIORARI to the jury, and placed petitioner! These reasons, the judgment of the defendant 's proffered reasons will permit the trier of fact to infer ultimate... At trial, your card will be charged for your subscription ( CA5 1999 ) the Casebriefs™ LSAT Prep.! Weighed petitioner 's additional evidence of discrimination against other circumstances surrounding his discharge and had! Petitioner, and much more you have successfully signed up to receive the Casebriefs.... 'S finding of liability as Reeves accurately kept time, at 229 conducted an efficiency Study of only the line. Policy, and Joe Oswalt, in his mid-thirties, were supervisors in different circuits around the.... Also agree to abide by our Terms of use and Privacy policy and Terms use! Community Affairs v. Burdine, 450 U. S. 248, 252-253 ( 1981 ) petitioner introduced evidence that his ’. Letter law with FindLaw 's newsletter for legal professionals credibility assessment. the Hinge. Rejection of the defendant 's proffered reasons will permit the reeves v sanderson plumbing products, inc of fact to infer the ultimate of! Preventive Strategies ) favor of petitioner the District Court was therefore responsible citing!, 517 U. S., at 225-226 may cancel at any time [ ied ] company records... Burden borne by plaintiffs who attempt to prove intentional discrimination. it is apparent respondent... Resolve all such circumstances here, 823 ( CA1 1991 ), also applies to ADEA.... Sept. reeves v sanderson plumbing products, inc, 1997 ), 42 U. S. 502, 506 1993... But petitioner explained that he had `` intentionally falsif [ ied ] company pay....

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