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St. Mary’s Honor Center v. Hicks
United States Supreme Court
509 U.S. 502 (1993)
Melvin Hicks (plaintiff), a Black man, worked for St. Mary’s Honor Center (St. Mary’s) (defendant). He was promoted from correctional officer to a supervisory position as a shift commander. After several disciplinary actions, Hicks was discharged from his position. Hicks brought suit against St. Mary’s under Title VII, alleging that he was discharged on the basis of his race. At trial, Hicks established a prima facie case of racial discrimination, thereby creating a presumption that St. Mary’s intentionally discriminated against Hicks based on his race. St. Mary’s offered evidence that Hicks was discharged for legitimate, nondiscriminatory reasons to rebut the presumption. Specifically, St. Mary’s pointed to Hicks’s numerous rule violations. The district court judge, acting as the fact-finder, found that the reasons given by St. Mary’s were not credible. However, the court ultimately found for St. Mary’s because Hicks failed to meet his burden of proof and show that race was the determining factor for his discharge. On appeal, the Eighth Circuit reversed and remanded the district court’s decision. It held that the finding that St. Mary’s reasons for discharging Hicks were mere pretexts entitled Hicks to judgment as a matter of law because the presumption of discrimination had not been rebutted. The United States Supreme Court granted certiorari.
Rule of Law
Holding and Reasoning (Scalia, J.)
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