SW Legal studies in Business

Meeting McDonnell Douglas Test Establishes Prima Facie Case of Employment Discrimination
Description Supreme Court held that if an employee files a complaint against an employer for employment discrimination, as long as the McDonnell Douglas four-part test has been met the employee has provided enough for the complaint to proceed; no specific facts to prove discrimination need be provided in the complaint.
Topic Employment Discrimination
Key Words Complaint; Prima Facie Case; McDonnell Douglas Test; Burden
C A S E   S U M M A R Y
Facts Swierkiewicz, a 53-year-old native of Hungary, sued his former employer claiming that he had been fired on account of his national origin and age. The trial court dismissed the suit, holding that he failed to meet his burden to establish a prima facie case of discrimination as required by the McDonnell Douglas test. The appeals court affirmed the dismissal; Scierkiewicz appealed.
Decision

Reversed. An employment discrimination complaint need not contain specific facts to establish a prima facie case under the McDonnell Douglas framework, but instead need contain only "a short and plain statement of the claim showing that the pleader is entitled to relief." All the plaintiff need show is 1) membership in a protected group, 2) qualification for the job in question, 3) an adverse employment action, and 4) circumstances supporting an inference of discrimination. Specific facts beyond that need not be demonstrated in the complaint. A court may dismiss such a complaint only if it is clear that no relief could be granted under any set of facts that could be proved consistent with the allegations.

Citation Swierkiewicz v. Sorena N.A., 122 S. Ct. 992 (Sup. Ct., 2002)

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