Reeves v. Sanderson Plumbing Products, Inc

In Reeves v. Sanderson Plumbing Products, Inc., 530 U.S. 133, 120 S. Ct. 2097, 147 L. Ed. 2d 105 (2000), the United States Supreme Court considered whether proof of a prima facie case of employment discrimination plus the jury's rejection of defendants' reasons for firing the employee are sufficient to permit a jury verdict in favor of the employee. Reeves, supra, was a case of discrimination under the Age Discrimination in Employment Act of 1967 (ADEA), 29 U.S.C.A. 621 to 634. The jury returned a verdict for the plaintiff and the District Court denied the defendant's motion for judgment as a matter of law. Reeves, supra, 530 U.S. at 139, 120 S. Ct. at 2104, 147 L. Ed. 2d at 114-15. The Fifth Circuit Court of Appeals reversed, entering judgment for the defendant. Ibid. The Supreme Court granted certiorari "to resolve a conflict among the Courts of Appeals as to whether a plaintiff's prima facie case of 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." Reeves, supra, 530 U.S. at 140, 120 S. Ct. at 2104, 147 L. Ed. 2d at 114. In Reeves, supra, the Supreme Court ruled that the Court of Appeals had "erred in proceeding from the premise that a plaintiff must always introduce additional, independent evidence of discrimination" in addition to a prima facie case and proof that the employer's explanation was mendacious. Ibid. But that conclusion did not decide the case. Having enunciated a rule of law, the Court proceeded to answer the "remaining question . . . whether, despite the Court of Appeals' misconception of petitioner's evidentiary burden, respondent was nonetheless entitled to judgment as a matter of law." Ibid. The court then summarized the evidence tending to show age discrimination and held that it was sufficient to support the jury's verdict. Id. at 530 U.S. 150, 120 S. Ct. at 2110-12, 147 L. Ed. 2d at 121-24.