REEVES v. SANDERSON PLUMBING PRODUCTS, INC. CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT No. By: Leizer Goldsmith. Id . 2000), the plaintiff filed a Title VII and related state-law lawsuit against Tulane University. On the basis of this evidence, the trier of fact concluded that the defendant's explanation for the termination was pretext and returned a verdict in favor of the Plaintiff. The case, Reeves v. Sanderson Plumbing Products, Inc. , involved allegations of age discrimination (see lead story in Spring 2000 Preventive Strategies ). The case of Reeves v. Sanderson Plumbing Products, Inc., ___S. Google Chrome, 1990); see also Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133, 147, 120 S. Ct. 2097, 2108 (2000) (“In appropriate circumstances, the trier of fact can reasonably infer from the falsity of [an] explanation that the employer is dissembling to cover up a … A recent Supreme Court decision, Reeves v. Sanderson Plumbing Products, 120 S. Ct. 2097 (2000), resolved an important disagreement among the lower federal courts over the legal standards which will govern an employer’s motion for summary judgment. She then turned to the next stage of the McDonnell Douglas burden-shifting framework to determine whether the defendant had then provided adequate evidence that the employment decision in question had been made for "a legitimate, nondiscriminatory reason. 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. “The United States Supreme Court has issued what is likely to be the most important employment discrimination ruling of the past seven years,” reports Chicago Lawyer magazine. Sandra Day O’Connor: Reeves v Sanderson Plumbing Products SYLLABUS. However, in agreeing to review the case, the Supreme Court considered the general conflict among the federal courts over the kind and amount of evidence necessary to prove intentional discrimination. This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. In Reeves v.Sanderson Plumbing Products, the justices unanimously ruled that employees can prove they are victims of age discrimination by showing that the reason the employer gives for their firing is false and … Id . 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. Sanderson has, at all times, supported its decision to fire Reeves with the charge that Reeves's work performance was unsatisfactory. Petitioner worked in a department known as the “Hinge Room,” where he supervised the “regular line.” Caldwell reported a drop in production in the summer of 1995 to the director of manufacturing, Powe Chesnut, who was also married to the president of the company, Sandra Sanderson. In support of his claim, appellant referenced a conversation he had with the Dean of the School of Engineering in which the Dean apparently speculated that the Chair of the Mechanical Engineering Department might be discriminating against appellant because he was Russian and Jewish. He alleged that Chesnut "had demonstrated age-based animus" while they were working together, and that he had "absolute power" to make employment decisions, due to his position and his relationship with the president of the company. [11], After determining that the trial court could have found in favor of Reeves, O'Connor turned to examining the procedural questions at hand. Fifty-seven year old Reeves was employed for 40 years by Sanderson — a company involved in the manufacture of toilet seats and covers. [7] On this point, the court noted that most of the defendant's evidence for nondiscrimination was negated by the plaintiff at trial, and also that the Fifth Circuit agreed, but did not find this to be sufficient for a ruling in favor of Reeves. 99–536. Chesnut recommended to Sanderson that she fire Reeves and Caldwell, and in October 1995, she followed that recommendation. Chesnut and other company officials recommended to the company president, Sandra Sanderson, that Reeves and Caldwell be fired, and she complied. Facts. 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. Hicks, 509 U.S. 502 (1993). Copyright © 2020, Thomson Reuters. Cir. of Community Affairs v. Burdine, https://en.wikipedia.org/w/index.php?title=Reeves_v._Sanderson_Plumbing_Products,_Inc.&oldid=906774230, United States employment discrimination case law, United States Supreme Court cases of the Rehnquist Court, Creative Commons Attribution-ShareAlike License, This page was last edited on 18 July 2019, at 04:30. (quoting Reeves , 2000 WL 743663, *5). Pp. On June 12, 2000, the United States Supreme Court issued the decision of Reeves v. Sanderson Plumbing Inc., U.S., 120 S.Ct. 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 v. Sanderson, 530 U.S. 133 (2000) Workplace Equality and Economic Empowerment; Year: 2000. The holdings in Feliciano, Williams, Weinstock, and Rubinstein suggest that some circuits view the Reeves decision as a distinguishable anomaly, whose holding is driven more by the facts of the case than the proscriptions in the anti-discrimination laws. at 2109. See id. Further, the Court of Appeals held that there was an overall lack of evidence of discriminatory intent, stating, A[w]hile we are mindful of the Supreme Court's recent admonition that Title VII plaintiffs need not always present evidence above and beyond their prima facie case and pretext, discrimination suits still require evidence of discrimination. It has been approximately three months since the release of this opinion and one could argue that the case has done little to ease a plaintiff's burden. The court below held that an employer who is accused of intentional discrimination based on the bias of a subordinate employee who provided information leading to the chal- lenged employment decision but was not involved in the decision itself can never obtain summary judgment unless it 98-30777 (5 th Cir. Tulane offered as its legitimate nondiscriminatory reason the fact that Rubinstein was a poor teacher, that the University lacked funds to give raises to every professor, and that Rubinstein was a poor university citizen, as evidenced by his lack of participation on committees. The Court held that these remarks were .stray remarks. 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 … ultimate employment decision. No. Early decisions, however, indicate that the Fifth Circuit will do little to change its analysis of employment discrimination cases. Reeves v. Sanderson Plumbing Products, Inc., 530 U. S. 133, 148 (2000) (“[A] plaintiff’s prima facie case, combined with sufficient evidence to find that the employer’s as-serted justification is false, may permit the trier of fact to conclude that the employer unlawfully discriminated”). [2] That case ended with the judge instructing the jury that Reeves must prove that age "was a determinative or motivating factor" in the employment decision in order to find in favor of the plaintiff, and the jury returned a verdict awarding Reeves $35,000 in compensatory damages and an additional $35,000 in liquidated damages based on the willfulness of the discrimination. 338-341. With the release of this opinion, many thought that a plaintiff's burden of proof had been lifted somewhat, the full extent, however, many did not know. Reeves' duties included making sure workers under his supervision were on time and at work and logging such data. At trial, Sanderson contended that Reeves was fired because of his failure to maintain accurate attendance records. In 1995, 57-year-old Roger Reeves and Joe Oswalt, who was in his mid-thirties, were supervisors at Sanderson Plumbing Products, being managed by 45-year-old Russell Caldwell. Stay up-to-date with FindLaw's newsletter for legal professionals, Reeves v. Sanderson Plumbing Products, Inc.: What Impact Will It Have? It is especially interesting to see how the Fifth Circuit will react to the Reeves decision as it was the Fifth Circuit that the Supreme Court unanimously overturned. This decision arose out of the determination that the discriminatory comments made by Chesnut "were not made in the direct context of Reeves's termination". 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 evidence that the employer's asserted reason for its adverse employment action is false, regardless of whether additional evidence of discrimination is presented. VI. 2097, 2110 (June 12, 2000). Roger Reeves (plaintiff), a 57-year-old, brought suit against his former employer, Sanderson Plumbing Products, Inc. (Sanderson) (defendant) under the Age Discrimination in Employment Act (ADEA), alleging that his discharge from Sanderson was impermissibly based on his age. See Reeves v. Sanderson Plumbing Prods ., 530 U.S. 133, 146-47 (2000) (clarifying that a false explanation by the employer permits, but does not require, a finding that discrimination played a part in the decision); Wilson v. Dr. Seldin, however, denied this contention in his deposition. 99-536 Argued: March 21, 2000 Decided: June 12, 2000. Reeves v. Sanderson Plumbing Products, Inc., 530 U. S. 133. Maybe None. Legal Momentun's Role: Joined Amicus Brief. In Feliciano v. El Conquistador Resort and CC, 99-1810, (1 st . The Court of Appeals held that while Rubinstein had produced some evidence of pretext on the issue of university citizenship, he had failed to produce evidence of pretext on the issue of poor teaching. Ct. ___ (2000), may apply to all discrimination cases, and not just those under the Age Discrimination in Employment Act (ADEA). The district court granted summary judgment to Davis on all three claims. "[6] That burden, too, was met, according to O'Connor's analysis. The holding in Chuang , on the other hand, suggests that there may be a few circuits who will strive to carve out a place for Reeves among their important precedents. This case lays out a framework for determining liability as part of the McDonnell Douglas burden-shifting framework, and clarifies parts of that framework as it applies to cases where the employer's reasons for making the decision are shown to be false. The Ninth Circuit, however, has used the Reeves to reverse the granting of summary judgment See Chuang v. University of California Davis, 99-15036 (9 th Cir. Id . [4], Justice O'Connor delivered the majority opinion. Under Reeves v. Sanderson Plumbing Products, Inc. , 530 U.S. 133 (2000), Bernofsky presented sufficient evidence to survive summary judgment on the issue of … [1], In June 1996, Reeves sued in the United States District Court for the Northern District of Mississippi under the Age Discrimination in Employment Act. The Court of Appeals, affirming summary judgment, drew a parallel with the Reeves decision holding that although their prior use of the label Apretext plus, may have resulted in a misunderstanding about the proof required for discrimination, they had been Acareful to explain that the phrase did not mean that the plaintiff always had to present evidence beyond proof of pretext. Last week's Supreme Court decision in Reeves v. Sanderson was primarily notable for the Court's clear statement that an older employee must be given his day in court to attempt to prove age discrimination to the jury, when younger persons were given his job after termination, and the company's explanations for its actions were arguably false. 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. 2000), plaintiff brought suit under Title VII, complaining of termination based on race. (c) On review of the record at this stage, this Court concludes that the District Court did not give full consideration to the substantial evidence petitioner put forth in support of the prima facie case. We recommend using Sanderson has, at all times, supported its decision to fire Reeves with the charge that Reeves's work performance was unsatisfactory. Opinion for Reeves v. Sanderson Plumbing Products, Inc., 530 U.S. 133, 120 S. Ct. 2097, 147 L. Ed. Petitioner worked in a department known as the "Hinge Room," where he supervised the "regular line." Columbia asserted as a legitimate nondiscriminatory reason the fact that Weinstock's scholarship was not up to its standards. 2d 105, 2000 U.S. LEXIS 3966 — Brought to you by Free Law Project, a non-profit dedicated to creating high quality open legal information. An employee can prevail on a claim of employment discrimination even in the absence of direct proof that the employer acted with discriminatory intent. She stated that such cases will be rare, because a dishonest defendant may be assumed to have some level of culpability, based on a fundamental principle of evidence law.[13]. The district court granted summary judgment and the plaintiff appealed. The Fifth Circuit went on to discount remarks made by professors on the promotion and pay raise committees. The trier of fact may reasonably find for the employer where the plaintiff makes only a weak showing of evidence as to the untruth of the employer's defense, or where there is ample evidence of another nondiscriminatory reason that the employer did not offer. Her first task was to set out the context of the case, starting with explaining that she would assume that McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973), was the relevant standard for analyzing a case brought under the ADEA, because nobody had disputed that fact, even though the court had never addressed that issue before. Reeves filed this suit, contending that he had been terminated because of his age in violation of the Age Discrimination in Employment Act of 1967 (ADEA). Specifically, Davis contended that Dr. Seldin, the presumptive Rowe Chair, demanded the precise space occupied by the Chuangs. Reeves filed suit, alleging that he had been terminated because of his age in violation of the Age Discrimination in Employment Act of 1967 (ADEA). 99-536. 197 F.3d 688, 690 (CA5 1999). In response, the Plaintiff offered specific evidence that he had properly maintained attendance records and that he was not responsible for the failure to discipline late and absent employees. at 2107. In this age discrimination case, Reeves alleged that the manager who fired him told him he was "too damn old." 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. Firefox, or Begin typing to search, use arrow keys to navigate, use enter to select. [5] She also noted that they would assume that the plaintiff met his burden in laying out a prima facie case against the defendant, because again, nobody had disputed that contention, and ample supporting evidence had been presented.[5]. [12], Justice Ginsburg concurred in the judgment but suggested that, because the court of appeals required Reeves to produce evidence that was neither a prima facie case nor evidence contradicting the defendant's proffered reasons, their decision could be overturned without any broader holding. Justice Ginsburg's opinion concurring in the judgment, United States District Court for the Northern District of Mississippi, Texas Dept. I FACTS AND PROCEEDINGS. The appellant claimed that he was denied raises and promotions out of discriminatory animus directed toward his status as a Russian Jew. The Court stated that although it found that appellants explanations of her job performance problems generated a triable issue of pretext, they found her evidence of pretext thin and that appellant's evidence did not shed any light on the true reason for her termination, let alone show that the reason was discrimination based on appellant's Puerto Rican origin. 2000). The Court found that appellant's qualifications were extraordinary and yet he was the only full-time faculty member in his department who had not received a tenured position. Her first task was to set out the context of the case, starting with explaining that she would assume that McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973), was the relevant standard for analyzing a case brought under the ADEA, because nobody had disputed that fact, even though the court had never addressed that issue before. ii PARTIES TO THE PROCEEDING Weinstock v. Columbia Univ., 99-7979 (2 nd Cir. at 143. All rights reserved. Seemingly, the singular truth about Reeves is that only time will tell its significance. Last month the U.S. Supreme Court issued an opinion further clarifying the rules courts must use in deciding employment discrimination cases. Sanderson claimed that Reeves was terminated because he was responsible for numerous timekeeping errors and misrepresentations … In this regard, Weinstock has more than met her burden to obtain a trial on the merits. She determined that respondent had not been entitled to a judgment as a matter of law, both because there was a question of fact to be decided by a jury in evaluating the truth of the defendant's nondiscriminatory explanation, and because the court of appeals should have reviewed the entire record in a manner favorable to the nonmoving party, which in this case was Reeves. Please try again. 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