In St. Mary's Honor Center v. Hicks (1993) 509 U.S. 502, the United States Supreme Court clarified the rules governing the shifting burden of production and proof in Title VII discrimination cases, which California courts use as their guideline for purposes of discrimination claims brought under the FEHA: "The plaintiff . . . must first establish, by a preponderance of the evidence, a 'prima facie' case of racial discrimination." ( Id. at p. 506.) Where the plaintiff was demoted or discharged, the elements of the prima facie case can be established by showing: (1) that the plaintiff is a minority; (2) that he was qualified for the position; (3) that he was demoted from the position and/or discharged; (4) that the position was filled by a non-minority. (Ibid.) The presumption "places upon the defendant the burden of producing an explanation to rebut the prima facie case -- i.e., the burden of 'producing evidence' that the adverse employment actions were taken 'for a legitimate, nondiscriminatory reason.'" ( Id. at pp. 506-507)