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Texas Department of Community Affairs v. Burdine,
450 U.S. 248 (1981)
This case involved the gender discrimination claim of a female employee who
kept her resume on file for six months for a position that was ultimately given
to a man. Ms. Burdine filed suit in district court. That court found that the
testimony of the Defendant had sufficiently rebutted her allegations of discrimination
and ruled for the Defendant. The Fifth Circuit reversed this judgment, holding
that the defendant in a Title VII case bears the burden of proving, by a preponderance
of the evidence, the existence of legitimate, nondiscriminatory reasons for the
employment action and also must prove by objective testimony that those hired
were better qualified than the plaintiff.
The Supreme Court used this case to clarify the burden that a defendant carries
under the three-prong burden shifting test set forth in McDonnell Douglas.
This case has been used by all of the lower federal courts as a further refinement
of the McDonnell Douglas analysis. The Court said that the plaintiff’s
first burden, that of proving a prima facie case of discrimination, must be met
by a preponderance of the evidence. Furthermore, the plaintiff retains, at all
times, the ultimate burden of persuading the trier of fact that she was discriminated
against. If the plaintiff makes out a prima facie case of discrimination, the
burden that shifts to the defendant is one of production. The defendant does not
need to prove anything, but only must rebut the presumption of discrimination
created by the prima facie case with an explanation of why the action it took
was not discriminatory. The Court made clear that a defendant need not persuade
the finder of fact that it was actually motivated by the proffered reason. It
is sufficient the defendant’s evidence raises a genuine issue of fact as
to whether the defendant discriminated against the plaintiff. If the defendant
carries this very low burden of production, then the presumption raised by the
prima facie case falls out of the case, and the factual inquiry proceeds to the
ultimate question of discrimination.
In Burdine the Supreme Court said that the defendant in a Title VII
claim need not show that the individuals it hired were more qualified than the
plaintiff. An employer is free to choose between similarly qualified applicants
for nondiscriminatory reasons. The Court so held because it wished to make clear
that Title VII does not require that an employer give preferential treatment to
any particular category of individuals.
Burdine was remanded to the Fifth Circuit for disposition in accordance
with the clarifications of the McDonnell Douglas test set forth above.
For a more recent Supreme Court treatment of this subject, see Reeves v.
Sanders Plumbing Products, Inc., 120 S.Ct. 2097 (2000).
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