St. Mary's Honor Center v. Hicks, 509 U.S. 502 (1993) (Supreme Court of the United States)
St. Mary's Honor Center v.
Under the McDonnell Douglas/Burdine burden-shifting framework, does a factfinder's rejection of an employer's proffered nondiscriminatory reason require a finding of intentional discrimination in favor of the Title VII plaintiff, or does the plaintiff retain the ultimate burden of persuasion to prove discriminatory intent?
In a Title VII disparate-treatment case tried under the McDonnell Douglas/Burdine framework, the plaintiff at all times bears the ultimate burden of persuading the factfinder that the employer intentionally discriminated. A plaintiff's showing that the employer's stated reason is false (pretext) permits—but does not compel—the factfinder to infer discrimination. The employer's burden is one of production, not persuasion; rejecting the employer's explanation does not shift the ultimate burden to the employer nor mandate judgment for the plaintiff.
No. Disbelief of the employer's proffered reasons does not compel judgment for the plaintiff; the plaintiff retains the ultimate burden to prove intentional discrimination. The Supreme Court reversed the Eighth Circuit and reinstated the district court's judgment for the employer.
Hicks clarified that "pretext" is an evidentiary tool, not a shortcut to liability. It preserves the plaintiff's ultimate burden to prove discriminatory intent and prevents the employer's production burden from morphing into a burden of persuasion. In practice, Hicks influences jury instructions, motions for judgment as a matter of law, and summary judgment analyses: a plaintiff who proves pretext may win if the factfinder draws the inference of discrimination, but cannot demand judgment as a matter of law solely on that basis. Later, in Reeves v. Sanderson Plumbing Products, Inc. (2000), the Court reaffirmed that a plaintiff's prima facie case plus evidence of pretext can be sufficient for a jury to find discrimination, clarifying that Hicks did not impose a rigid "pretext-plus" requirement. For students, Hicks is essential to understanding the contours of the burden-shifting framework and the fine line between permissive inference and compelled finding.