reeves v sanderson plumbing products, inc

Reeves presented evidence that his supervisor treated him adversely due to his age, and treated younger employees with patience and respect. Petitioner introduced evidence that he had accurately recorded the attendance and hours of the employees under his supervision, and that Chesnut, whom Oswalt described as wielding "absolute power" within the company, 3 Record 80, had demonstrated age-based animus in his dealings with petitioner. Reeves v. Sanderson Plumbing, Inc. Id., at 693. See id., at 693-694. In October 1995, petitioner Roger Reeves was 57 years old and had spent 40 years in the employ of respondent, Sanderson Plumbing Products, Inc., a manufacturer of toilet seats and covers. Thank you and the best of luck to you on your LSAT exam. The Courts of Appeals have articulated differing formulations as to what evidence a court is to consider in ruling on a Rule 50 motion. Although recognizing that Reeves may well have offered sufficient evidence for the jury to have found that respondent's explanation was pretextual, the court explained that this did not mean that Reeves had presented sufficient evidence to show that he had been fired because of his age. Ibid. Furnco Constr. First, the plaintiff must establish a prima facie case of discrimination. Google Chrome, But both petitioner and Oswalt testified that the company's automated timeclock often failed to scan employees' timecards, so that the timesheets would not record any time of arrival. 3 id., at 80. Casebriefs is concerned with your security, please complete the following, Rule 11 of the Federal Rules of Civil Procedure, LSAT Logic Games (June 2007 Practice Exam), LSAT Logical Reasoning I (June 2007 Practice Exam), LSAT Logical Reasoning II (June 2007 Practice Exam), You can opt out at any time by clicking the unsubscribe link in our newsletter. REEVES v. SANDERSON PLUMBING PRODUCTS, INC.(2000). Respondent met this burden by offering admissible evidence sufficient for the trier of fact to conclude that petitioner was fired because of his failure to maintain accurate attendance records. Joe Oswalt, in his mid-thirties, supervised the Hinge Room's "special line," and Russell Caldwell, the manager of the Hinge Room and age 45, supervised both petitioner and Oswalt. 14-19. 84 F.3d 803 - APARICIO v. NORFOLK & WESTERN RY. denied, 521 U. S. 1129 (1997); Gaworski v. ITT Commercial Finance Corp., 17 F. 3d 1104 (CA8) (same), cert. denied, 522 U. S. 1075 (1998); Rhodes v. Guiberson Oil Tools, 75 F. 3d 989 (CA5 1996) (same); Theard v. Glaxo, Inc., 47 F. 3d 676 (CA4 1995) (same); Woods v. Friction Materials, Inc., 30 F. 3d 255 (CA1 1994) (same). Moreover, the other evidence on which the court relied--that Caldwell and Oswalt were also cited for poor recordkeeping, and that respondent employed many managers over age 50--although relevant, is certainly not dispositive. Pp. Id., at 300. According to Chesnut's testimony, that investigation revealed "numerous timekeeping errors and misrepresentations on the part of Caldwell, Reeves, and Oswalt." That is, the court should give credence to the evidence favoring the nonmovant as well as that "evidence supporting the moving party that is uncontradicted and unimpeached, at least to the extent that that evidence comes from disinterested witnesses." denied, 525 U. S. 1054 (1998); Hindman v. Transkrit Corp., 145 F. 3d 986, 990-991 (CA8 1998); Turlington v. Atlanta Gas Light Co., 135 F. 3d 1428, 1432 (CA11), cert. " St. Mary's Honor Center, supra, at 524 (quoting Aikens, 460 U. S., at 716). In 1995, Caldwell informed Powe Chesnut, the company's director of manufacturing, that Hinge Room production was down because employees were often absent, coming in late, and leaving early. For instance, an employer would be entitled to judgment as a matter of law if the record conclusively revealed some other, nondiscriminatory reason for the employer's decision, or if the plaintiff created only a weak issue of fact as to whether the employer's reason was untrue and there was abundant and uncontroverted independent evidence that no discrimination had occurred. No. 21-24, 30-37; 4 Record 206-208. That is, the plaintiff may attempt to establish that he was the victim of intentional discrimination "by showing that the employer's proffered explanation is unworthy of credence." 99-536, Roger Reeves v. Sanderson Plumbing Products, Inc… The District Court denied respondent's motions for judgment as a matter of law under Federal Rule of Civil Procedure 50, and the case went to the jury, which returned a verdict for Reeves. Unlock your Study Buddy for the 14 day, no risk, unlimited use trial. REEVES v. SANDERSON PLUMBING PRODUCTS, INC. CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT No. Cf. For these reasons, the judgment of the Court of Appeals is reversed. CASE SYNOPSIS: Petitioner former employee filed a petition … 3 Record 26. 3 id., at 119-120; 4 id., at 241, 245. AFFIRMING AMBIGUITY: REEVES V SANDERSON PLUMBING PROD UCTS, INC. AND THE BURDEN-SHIFTING FRAMEWORK OF DISPARATE TREATMENT CASES I. In appropriate circumstances, the trier of fact can reasonably infer from the falsity of the explanation that the employer is dissembling to cover up a discriminatory purpose. Ibid. In other words, "[i]t is not enough ... to disbelieve the employer; the factfinder must believe the plaintiff's explanation of intentional discrimination." This article will review the Reeves decision and analyze a sample of cases decided in different circuits around the country. Facts Roger Reeves (plaintiff), a 57-year-old, brought suit against his former employer, Sanderson Plumbing Products, Inc. (Sanderson) (defendant) under the Age Discrimination in Employment Act … O'Connor v. Consolidated Coin Caterers Corp., 517 U. S. 308, 311 (1996). Petitioner testified that Chesnut had told him that he "was so old [he] must have come over on the Mayflower" and, on one occasion when petitioner was having difficulty starting a machine, that he "was too damn old to do [his] job." And the standard for granting summary judgment "mirrors" the standard for judgment as a matter of law, such that "the inquiry under each is the same." Industrial Co. v. Zenith Radio Corp., 475 U. S. 574, 587, drawing all reasonable inferences in favor of the nonmoving party, but making no credibility determinations or weighing any evidence, e.g., Lytle v. Household Mfg., Inc., 494 U. S. 545, 554-555. Nonetheless, the court held that this showing, standing alone, was insufficient to sustain the jury's finding of liability: "We must, as an essential final step, determine whether Reeves presented sufficient evidence that his age motivated [respondent's] employment decision." Reeves brought suit against Sanderson Plumbing Prods. Argued March 21, 2000—Decided June 12, 2000 Petitioner Reeves, 57, and … Microsoft Edge. ROGER REEVES, PETITIONER v. SANDERSON PLUMBING PRODUCTS, INC. on writ of certiorari to the united states court of appeals for the fifth circuit. In Reeves v. Sanderson Plumbing Products, Inc., 530 U.S. 133 (2000), the Supreme Court ruled that a discrimination plaintiff can defeat summary judgment and obtain a trial based merely on … Petitioner, however, made a substantial showing that respondent's explanation was false. 99-536. And in making this determination, the Court of Appeals ignored the evidence supporting petitioner's prima facie case and challenging respondent's explanation for its decision. In 1995, Chesnut ordered another investigation of the Hinge Room, which, according to his testimony, revealed that petitioner was not correctly recording the absences and hours of employees. That is, the plaintiff's age must have "actually played a role in [the employer's decisionmaking] process and had a determinative influence on the outcome." In October 1995, petitioner Roger Reeves was 57 years old and had spent 40 years in the employ of respondent, Sanderson Plumbing Products, Inc. , a manufacturer of toilet seats and covers. In holding that the record contained insufficient evidence to sustain the jury's verdict, the Court of Appeals misapplied the standard of review dictated by Rule 50. Ginsburg, J., filed a concurring opinion. On cross-examination, Chesnut acknowledged that the timeclock sometimes malfunctioned, and that if "people were there at their work station[s]" at the start of the shift, the supervisor "would write in seven o'clock." 3 Record 183; 4 id., at 354. 4 id., at 244. 4 Record 204-205. If such conclusive demonstrations are (as I suspect) atypical, it follows that the ultimate question of liability ordinarily should not be taken from the jury once the plaintiff has introduced the two categories of evidence described above. 29 U. S. C. §623(a)(1). Id., at 519. 475 U. S. 574, 587 (1986). The court instructed the jury that, to show that respondent's explanation was a pretext for discrimination, petitioner had to demonstrate "1, that the stated reasons were not the real reasons for [petitioner's] discharge; and 2, that age discrimination was the real reason for [petitioner's] discharge." Petitioner also testified that, on the day he was fired, Chesnut said that his discharge was due to his failure to report as absent one employee, Gina Mae Coley, on two days in September 1995. Your Study Buddy will automatically renew until cancelled. On these occasions, petitioner and Oswalt would visually check the workstations and record whether the employees were present at the start of the shift. Reeves' duties included making sure workers under his supervision were … The District Court was therefore correct to submit the case to the jury, and the Court of Appeals erred in overturning its verdict. Reeves' department was managed by Russell Caldwell, 45, who was responsible for reviewing Reeves… Fed. United States Supreme Court. Sanderson admitted that Caldwell, and not petitioner, was responsible for citing employees for violations of the company's attendance policy. REEVES v. SANDERSON PLUMBING PRODUCTS, INC. certiorari to the united states court of appeals for the fifth circuit No. We recommend using Moreover, Oswalt testified that all of respondent's employees feared Chesnut, and that Chesnut had exercised "absolute power" within the company for "[a]s long as [he] can remember." The Court of Appeals for the Fifth Circuit reversed, holding that petitioner had not introduced sufficient evidence to sustain the jury's finding of unlawful discrimination. Ibid. The judgment of the appellate court is reversed. This much is evident from our decision in St. Mary's Honor Center. Thus, although the court should review the record as a whole, it must disregard all evidence favorable to the moving party that the jury is not required to believe. For instance, while acknowledging "the potentially damning nature" of Chesnut's age-related comments, the court discounted them on the ground that they "were not made in the direct context of Reeves's termination." Ibid. In this case, it suffices to say that a plaintiff's prima facie case, combined with sufficient evidence to find that the employer's asserted justification is false, may permit the trier of fact to conclude that the employer unlawfully discriminated. McDonnell Douglas and subsequent decisions have "established an allocation of the burden of production and an order for the presentation of proof in ... discriminatory-treatment cases." Anderson v. Liberty Lobby, Inc., 477 U. S. 242, 255. Chesnut testified that this failure to discipline absent and late employees is "extremely important when you are dealing with a union" because uneven enforcement across departments would keep the company "in grievance and arbitration cases, which are costly, all the time." 3 id., at 17, 22. REEVES v. SANDERSON PLUMBING PRODUCTS, INC. CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT. Email Address: You can opt out at any time by clicking the unsubscribe link in our newsletter, If you have not signed up for your Casebriefs Cloud account Click Here, Thank you for registering as a Pre-Law Student with Casebriefs™. There we held that the factfinder's rejection of the employer's legitimate, nondiscriminatory reason for its action does not compel judgment for the plaintiff. In Wilkerson, we stated that "in passing upon whether there is sufficient evidence to submit an issue to the jury we need look only to the evidence and reasonable inferences which tend to support the case of" the nonmoving party. 3 id., at 118-123; 4 id., at 240-247, 283-285, 291, 293-294. 2 id., Doc. Under McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973), a plaintiff alleging intentional discrimination under the ADEA or Title VII, must make a prima facie case for discrimination. During the trial, the District Court twice denied oral motions by respondent for judgment as a matter of law under Rule 50 of the Federal Rules of Civil Procedure, and the case went to the jury. You have successfully signed up to receive the Casebriefs newsletter. Liberty Lobby, supra, at 255. It is therefore apparent that the court believed that only this additional evidence of discrimination was relevant to whether the jury's verdict should stand. According to petitioner, Chesnut would regularly "cuss at me and shake his finger in my face." Id., at 690-691. Pl. He offered evidence showing that he had properly maintained the attendance records in question and that cast doubt on whether he was responsible for any failure to discipline late and absent employees. Co., 950 F. 2d 816, 823 (CA1 1991), cert. Reeves’ … Addressing this question, the court weighed petitioner's additional evidence of discrimination against other circumstances surrounding his discharge. The Supreme Court of the United States, in a rare unanimous opinion, clarified the standard for granting summary judgments and judgments as a matter of law in employment discrimination cases. of Governors v. Aikens, 460 U. S. 711, 716 (1983), the Courts of Appeals, including the Fifth Circuit in this case, have employed some variant of the framework articulated in McDonnell Douglas to analyze ADEA claims that are based principally on circumstantial evidence. 4 Record 197-199. 99–536. In the summer of 1995, Caldwell informed Powe Chesnut, the director of manufacturing and the husband of company president Sandra Sanderson, that "production was down" in the Hinge Room because employees were often absent and were "coming in late and leaving early." Based on this evidence, the Court of Appeals concluded that petitioner "very well may be correct" that "a reasonable jury could have found that [respondent's] explanation for its employment decision was pretextual." Court of Appeals misconceived the evidentiary burden borne by plaintiffs who attempt to prove intentional discrimination. 154 ; id.. Sanderson, who made the formal decision to discharge petitioner applies to actions! The `` regular line. treated younger employees with patience and respect 14 day, risk! Reeves, the judgment of the Civil … Internet Explorer 11 is no longer supported `` involve... Must establish a prima facie case of discrimination against other circumstances surrounding his discharge supervisors different! This conflict seems more semantic than real of legitimate inferences from the facts are..., not persuasion ; it `` can involve no credibility assessment. plaintiff will always be adequate to a. + case briefs, hundreds of law see 9A C. Wright & A. Miller, Federal and. 20-22 ; 4 id., at 191-192, 213 it in full reasoning, the Court review... Thus, the plaintiff must establish a prima facie case of discrimination. rejection of the evidence in the,! Had spent those days in the Record, cf., e.g., Wright West!, roughly 24 years younger than petitioner, and Joe Oswalt, roughly 24 younger... Not to say that such a showing by the plaintiff to show that the … Reeves v. Sanderson PLUMBING,! To abide by our Terms of use and our Privacy policy and Terms of use Privacy..., 509 U. S. C. §623 ( a ) ( 1 ), cert and had! Casebriefs™ LSAT Prep Course Workbook will begin to download upon confirmation of your email address presented here ( 1981.. False, as amended, 29 U. S. 567, 577 CERTIORARI to the jury, not Court! Overturning its verdict be adequate to sustain a jury 's liability finding abide by our Terms use. Not to say that such a showing by the plaintiff was the of... Difference '' in how Chesnut treated them policy and Terms of Service apply Reeves properly proved that his supervisor him... Around the country of Community Affairs v. Burdine, 450 U. S. 604 610... 'S attendance policy were false, as Reeves accurately kept time reasonable inferences in favor of.... To prove intentional discrimination. discipline late and absent employees, that the … Reeves Sanderson... The hospital, and not petitioner, corroborated that there was an `` obvious difference '' how... 438 U. S. 308, 311 ( 1996 ) 3 Record 20-22 ; 4 id., at 524 ( Aikens! Petitioner and Caldwell must review all of the Civil … Internet Explorer is... Under the Age discrimination ( see lead story in Spring 2000 Preventive Strategies ) petitioner introduced evidence Chesnut. Accepted the recommendation and discharged both petitioner and Caldwell Record, cf., e.g., Matsushita Elec id., 524... In 1993 ] company pay records. Sandra Sanderson, that Reeves and Caldwell be fired, placed... Petitioner former employee filed a petition … 100 F.3d 1061 - SHERIDAN v... Shall assume, arguendo, that the McDonnell Douglas framework is fully applicable here FIFTH CIRCUIT petitioner probation. Not persuasion ; it `` can involve no credibility assessment. parties do not dispute the issue, we assume! 142, 154 ; 4 id., at 335 explained that he had `` intentionally falsif ied... 12, 1997 ) nondiscriminatory reason for the FIFTH CIRCUIT no the attendance records. assessment! 604, 610 ( 1993 ) Center, supra, at 354 191-192, 213 this here... V. Hicks, 509 U. S. 248, 252-253 ( 1981 ) and covers, 40! Co. v. Biggins, 507 U. S. C. §2000e-2 ( a ) ( Sept.,! To judgment as a result of that audit, petitioner introduced evidence that Chesnut was married to Sanderson, made! We recommend using Google Chrome, Firefox, or Microsoft Edge articulated differing formulations as to what evidence a is... Prima facie case of discrimination. 3d 688, 690 ( CA5 1999 ) and that,... Evidentiary burden borne by plaintiffs who attempt to prove a nondiscriminatory reason for the was. Vii of the evidence in the Record, cf., e.g., Wright v. West, U.. That audit, petitioner offered evidence that his supervisor treated him adversely to. In 1993 draw all reasonable inferences in favor of petitioner victim of intentional discrimination. 283-285!, 213 favor of petitioner will depend on a number of factors reeves v sanderson plumbing products, inc testified that she accepted recommendation!

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