St. Mary’s Honor Center v. Hicks

Melvin Hicks (plaintiff), a Black man, worked for years as a correctional officer at St. Mary’s Honor Center (St. Mary’s) (defendant), a halfway house operated by the Missouri Department of Corrections. Initially, Hicks received satisfactory performance evaluations. However, shortly after St. Mary’s hired a new chief of custody and a new superintendent, Hicks started getting in trouble for violating rules. Hicks was suspended for five days, reprimanded, and demoted. Finally, Hicks threatened the chief of custody during an argument and was fired. Hicks sued St. Mary’s, alleging employment discrimination, specifically that he had been demoted and discharged because of his race in violation of Title VII of the Civil Rights Act of 1964. In a bench trial, the district court applied the McDonnell Douglas framework. Under the first step, Hicks established a prima facie case of racial discrimination by showing that he was a member of a protected class, he was qualified for his position, and his position had been filled by an individual of a different class after his termination. Under the framework’s second step, St. Mary’s responded with evidence that Hicks had been fired for legitimate reasons, namely rule violations. Hicks then satisfied the third and final step of the McDonnell Douglas framework by showing that what St. Mary’s claimed as legitimate reasons were pretextual and false. However, the district court added a fourth step and required that Hicks establish that the true, hidden reason why St. Mary’s had terminated Hicks was intentional discrimination. Because Hicks could not prove that race was the determining factor in his discharge, the district court entered judgment for St. Mary’s. The Eighth Circuit reversed, ruling that there was no fourth step, but rather that once Hicks proved that the termination reasons claimed by St. Mary’s were false, he was entitled to judgment. The United States Supreme Court granted certiorari.