Mr. Gardner. v. HICKS certiorari to the united states court of appeals for the eighth circuit No. JJ., joined. Media for St. Mary's Honor Center v. Hicks. Whereas we said in Burdine that if the employer carries its burden of production, "the factual inquiry proceeds to a new level of specificity," 450 U.S., at 255, 101 S.Ct., at 1095, the Court now holds that the further enquiry is wide open, not limited at all by the scope of the employer's proffered explanation.10 Despite the Court's assiduous effort to reinterpret our precedents, it remains clear that today's decision stems from a flat misreading of Burdine and ignores the central purpose of the McDonnell Douglas framework, which is "progressively to sharpen the inquiry into the elusive factual question of intentional discrimination." Opinion for Hicks v. St. Mary's Honor Center, 756 F. Supp. 17-22. introducing evidence of two legitimate, nondiscriminatory reasons for Id., at 258, 101 S.Ct., at 1096 (internal quotation marks omitted); see id., at 256, 101 S.Ct., at 1095 (the plaintiff "must have the opportunity to demonstrate" pretext); Aikens, supra, at 716, n. 5, 103 S.Ct., at 1482; Furnco, 438 U.S., at 578, 98 S.Ct., at 2950; McDonnell Douglas, 411 U.S., at 805, 93 S.Ct., at 1825-1826. Melvin Hicks appeals from a final judgment entered in the United States District Court 1 for the Eastern District of Missouri in favor of his former employer, St. Mary's Honor Center (St. Mary's), and the superintendent of St. Mary's, Steve Long (together defendants), on his claims arising under Title VII and the equal protection clause. 88-109C(5) (E.D. CASE ANALYSIS: (1993) ST. MARY’S HONOR CENTER V. HICKS 2 Case Analysis Melvin Hicks worked for a minimum security prison in Missouri. In Hicks, the Court reaffirmed what it had said in United States Postal Services Board of Governors v. Aikens, 460 U.S. 711, 716 (1983): [Tihe question facing triers of fact in discrimination cases is both sensi-tive and difficult. presentation of proof in Title VII discriminatory treatment cases that Jun 25, 1993. discriminated. Argued April 20, 1993—Decided June 25, 1993 Petitioner halfway house employed respondent Hicks as a correctional of-ficer and later a shift commander. that the trier of fact's disbelief of petitioners' proffered reasons placed makes plain the purpose of Congress to assure equality of employment opportunities and to eliminate those discriminatory practices Lower court United States Court of Appeals for the Eighth Circuit . ultimately persuasive or not, satisfied their burden of production and Apr 20, 1993. In St. Mary's Honor Center v. Hicks, a closely-divided Supreme Court substantially altered the McDonnell Douglas framework. This Note examines the St. Mary's Honor Center v. Hicks decision and its likely effects on future Title VII disparate treatment claims. employer's explanation of its action was not believable. 2. The To demonstrate discrimination, an employee must conform under Title VII of the Civil Rights Act of 1964 (Cundiff, & Chaitovitz, 1994). Media. Petitioner St. Mary’s Honor Center (St. Mary’s) is a halfway house operated by the Missouri Department of Corrections and Human Resources (MDCHR). 1244 (E.D. that the Title VII plaintiff at all times bears the ultimate burden of 1997). of Community Affairs v. Burdine, 450 U.S. 248, 252-253, Rappaport: St. Mary's Honor Center v. Hicks: Has the Supreme Court Turned It Published by Villanova University Charles Widger School of Law Digital Repository, 1994. 1 . Docket no. 92-602 . Syllabus ; View Case ; Petitioner St. Mary's Honor Center et al. 3 . Argued April 20, 1993—Decided June 25, 1993 Petitioner halfway house employed respondent Hicks as a correctional of-ficer and later a … ST. MARY'S HONOR CENTER v. HICKS AND THE BURDENS OF PROOF IN EMPLOYMENT DISCRIMINATION CASES. Apr 20, 1993. eliminated by United States Postal Service Bd. 1. Respondent Melvin Hicks, a black man, was hired as a correc= tional officer at St. Mary=E2=80=99s in August 1978 and was promoted to shi= ft commander, one of six supervisory positions, in February 1980. Hicks v. St. Mary's Honor Ctr., No. Citation 509 US 502 (1993) Argued. The district court reaffirmed its findings of fact from its 1991 decision and declared those findings applicable to both the issue of whether defendants' personal animosity toward plaintiff was racially motivated and plaintiff's retaliation claim. . Id. filed a dissenting opinion, in which White, Blackmun, and Stevens, Id., at 255, n. 8, 101 S.Ct., at 1094, n. 8. NOTE: Where it is feasible, a syllabus (headnote) will be released, as is Oral Argument - April 20, 1993; Opinions. BACKGROUND A. The Seventh Circuit has held in one case that where the defendant asserts several reasons for its decision, the plaintiff may not normally survive summary judgment by refuting only one of the reasons. The Court remains in session. Melvin Hicks was hired as a correctional officer at St. Mary's in August 1978 and was promoted to a supervisory position, shift commander, in February 1980. 3. Oral Argument - April 20, 1993. (a) Under McDonnell Douglas, once Hicks established, by a - Description: U.S. Reports Volume 509; October Term, 1992; St. Mary's Honor Center et al. 92-602, St. Mary’s Honor Center v. Souter, J., created by a dictum in Burdine that falsity of the employer's Coco v. ST. MARY'S HONOR CENTER, et al., PETITIONERS v. MELVIN HICKS on writ of certiorari to the united states court of appeals for the eighth circuit [June 25, 1993] Justice Scalia delivered the opinion of the Court. Oral Argument - April 20, 1993; Opinions. Scalia, joined by Rehnquist, O'Connor, Kennedy, Thomas, Souter, joined by White, Blackmun, Stevens, This page was last edited on 5 October 2020, at 20:09. 2 McDonnell Douglas established a tripartite burden-shifting analysis for proving intentional discrimination by the employer, that is, for The Note begins with a brief review of the case law governing the burden of proof and then outlines the facts and procedural history of the Hicks case, including both the majority and dissenting opinions. § 2000e, and Long had violated 42 U.S.C. Discrediting the reasons offered by the employer for its decision no longer suffices to establish a violation of Title VII. Nor may the Court substitute for that required 2. . 126, 146, 727 F.2d 1225, 1245 (1984) (Scalia, J., dissenting) ("[I]n order to get to the jury the plaintiff would . 84 James R. Neely, Jr., Deputy General Counsel of the EEOC, Preliminary Guidance Ante, at ____. Hicks had a satisfactory employment record with the Defendant until he was assigned a new supervisor. St. Mary's Honor Center v. Hicks, 509 U.S. at 511; Anderson v. Baxter Healthcare Corp., 13 F.3d 1120, 1123 (7th Cir. The District Court (Stephen N. Limbaugh Sr.), found that (1)(a) the employee had established a prima facie case of racial discrimination, and (b) the reasons that the employer gave for the demotion and discharge were not the real reasons for the demotion and discharge, but that (2) the employee had failed to carry his ultimate burden of proving that his race was the determining factor in the employer's allegedly discriminatory actions. prepared by the Reporter of Decisions for the convenience of the reader. St. Mary's Honor Ctr. Apr 20, 1993. VILLANOVA LAW REVIEW. to disbelieve the employer." . But other language in the Court's opinion supports a more extreme conclusion, that proof of the falsity of the employer's articulated reasons will not even be sufficient to sustain judgment for the plaintiff. Petitioners' DuPont de Nemours and Co. After being demoted and Respondent Melvin Hicks, a black man, was hired as a correctional officer at St. Mary’s in August 1978 and was promoted to shift commander, one of six supervisory positions, in February 1980. Any doubt factfinder determines that the employer has unlawfully This Note examines the St. Mary's Honor Center v. Hicks decision and its likely effects on future Title VII disparate treatment claims. For the majority, Scalia J held (joined by Rehnquist, O'Connor, Kennedy, and Thomas) even if a plaintiff discredits an employer’s explanation, the employer can still win if the trier of fact concludes there was no discriminatory intent. v. Hicks, 509 U.S. 502 (1993). However, as in the case of all presumptions, see Fed. St. Mary’s Honor Center v. Hicks, 1 the United States Supreme Court revisited its landmark 1973 decision, McDonnell Douglas Corp. v. Green. CASE ANALYSIS: (1993) ST. MARY’S HONOR CENTER V. HICKS 2 Case Analysis Melvin Hicks worked for a minimum security prison in Missouri. St. Mary's Honor Center v. Hicks: Has the Supreme Court Turned Its Back on Title VII by Rejecting Pretext-Only Louis M. Rappaport Follow this and additional works at: https://digitalcommons.law.villanova.edu/vlr Part of the Civil Rights and Discrimination Commons, and the Labor and Employment Law Commons Melvin Hicks was an employee of Saint Mary's Center from 1978 to early 1984. 4. Media. 1244 — Brought to you by Free Law Project, a non-profit dedicated to creating high quality open legal information. Ante, at ____ (emphasis in original). In St. Mary's Honor Center v. Hicks, the Supreme Court held that a plaintiff in an employment discrimination suit must prove both a ... positions is significant. 92-602. See United States v. Detroit Lumber Co., 200 U.S. 321, 337. St. Mary’s Honor Center v. Hicks, 1 the United States Supreme Court revisited its landmark 1973 decision, McDonnell Douglas Corp. v. Green. The same view is implicit in the Court's decision to remand this case, ante, at ____, keeping Hicks's chance of winning a judgment alive although he has done no more (in addition to proving his prima facie case) than show that the reasons proffered by St. Mary's are unworthy of credence. Media. Hicks had the task of proving that St. Mary’s intentionally discriminated against him due to his skin color (Brodin, 1997). 1996] EMPLOYMENT lAW-RAMIFICATIONS OF Sr. M4Ry:S HONOR CENTER v..HICKS: THE THIRD CIRCUIT' S REVIVAL OF THE "PRETEXT-ONLY" STANDARD AT SUMMARY JUDGMENT Sheridan v. E.I. does not shift the burden of proof, and would ignore the admonition The possibility of some practical procedure for addressing what Burdine calls indirect proof is crucial to the success of most Title VII claims, for the simple reason that employers who discriminate are not likely to announce their discriminatory motive. ST. MARY'S HONOR CENTER et al. In the Court's own words, the plaintiff must "disprove all other reasons suggested, no matter how vaguely, in the record." L. Rev. Melvin Hicks appeals from a final judgment entered in the United States District Court1 for the Eastern District of Missouri in favor of his former employer, St. Mary's Honor Center (St. Mary's), and the superintendent of St. Mary's, Steve Long (together defendants), on his claims arising under Title VII and the equal protection clause. Under the majority's scheme, once the employer succeeds in meeting its burden of production, "the McDonnell Douglas framework . Scalia, J., delivered the opinion of the Court, in which Rehnquist, Decided . persuasion. For the reasons discussed below, we remand the case to the district court for further consideration in light of the Supreme Court's opinion. Brewer v. Quaker State Oil Riifining Co. unlawful discrimination did not cause their actions. §703(a)(1) of Title VII of the Civil Rights Act of 1964. Citation 509 US 502 (1993) Argued. C. J., and O'Connor, Kennedy, and Thomas, JJ., joined. Syllabus ; View Case ; Petitioner St. Mary's Honor Center et al. finding the much different and much lesser finding that the This "pretext-plus" approach would turn Burdine on its head, see n. 7, supra, and it would result in summary judgment for the employer in the many cases where the plaintiff has no evidence beyond that required to prove a prima facie case and to show that the employer's articulated reasons are unworthy of credence. St. Mary's Honor Center is a halfway house operated by the Missouri Department of Corrections and Human Resources. . . . After that, Hicks began to be singled out for reprimands, was demoted, and eventually was fired. For the reasons discussed below, we remand the case to the district court for further consideration in light of the Supreme Court's opinion. placed upon petitioners the burden of producing evidence that theadverse actions were taken for legitimate, nondiscriminatory reasons, 5. The majority fails to explain how the plaintiff, under its scheme, will ever have a "full and fair opportunity" to demonstrate that reasons not articulated by the employer, but discerned in the record by the factfinder, are also unworthy of credence. 1994) case opinion from the US Court of Appeals for the Eighth Circuit 92-602 . The majority's scheme greatly disfavors Title VII plaintiffs without the good luck to have direct evidence of discriminatory intent. ST. MARY’S HONOR CENTER et al. Petitioner St. Mary's Honor Center (St. Mary's) is a halfway house operated by the Missouri Department of Corrections and Human Resources (MDCHR). Spectators are warned and admonished not to talk until you get out of the courtroom. nonetheless held that Hicks had failed to carry his ultimate burden of The District Court's rejection of the employer's asserted reasons for its actions did not mandate a finding for the employee, because. Docket no. Respondent Hicks . petitioners came forward with an explanation. St. Mary's Honor Ctr. The Court of Appeals erred when it concluded 1287 (1996). v. HICKS certiorari to the united states court of appeals for the eighth circuit. Citation 509 US 502 (1993) Argued. (b) This Court has no authority to impose liability upon an Id., at 254-255, Souter J dissented (joined by White, Blackmun, and Stevens), arguing an employer would be better off presenting an untruthful explanation of its actions than presenting none at all. In one passage, the Court states that although proof of the falsity of the employer's proffered reasons does not "compe[l] judgment for the plaintiff," such evidence, without more, "will permit the trier of fact to infer the ultimate fact of intentional discrimination." explanation is alone enough to sustain a plaintiff's case was 2d 407 (1993), rev'g and remanding, 970 F.2d 487 (8th Cir. Pp. Decided by Rehnquist Court . Oral Argument - April 20, 1993; Opinions. No. 83 The two reasons offered by St. Mary's for Hicks's termination were "the severity and the accumulation of violations committed by plaintiff." 2742, 125 L.Ed.2d 407 (1993), rev'g and remanding, 970 F.2d 487 (8th Cir.1992), rev'g 756 F.Supp. him because of his race. We’ll hear argument next in No. and n. 8. 92–602. St. Mary’s Honor Center v. Hicks The St. Mary’s Center v. Hicks case created national storm after the Supreme Court decision that an employee must provide evidence and prove discrimination in the workplace. 92-602) Argument Date: April 20, 1993 ISSUE This case raises questions relating to proof issues and the structure of a disparate treatment case involving employment discrimination under Title VII of the Civil Rights Act of 1964. Three years later a state mandated examination was conducted which brought about broad authoritative modifications the following year. Hicks had proven that petitioners intentionally discriminated against No. And yet, under the majority's scheme, a victim of discrimination lacking direct evidence will now be saddled with the tremendous disadvantage of having to confront, not the defined task of proving the employer's stated reasons to be false, but the amorphous requirement of disproving all possible nondiscriminatory reasons that a factfinder might find lurking in the record. Docket no. at 1250. Burdine provides the answer, telling us that such a plaintiff may succeed in meeting his ultimate burden of proving discrimination "indirectly by showing that the employer's proffered explanation is unworthy of credence." Syllabus ; View Case ; Petitioner St. Mary's Honor Center et al. Petitioner St. Mary=E2=80=99s Honor Center (St. Mary=E2=80=99s) is a hal= fway house operated by the Missouri Department of Corrections and Human Res= ources (MDCHR). Id. . 2742, 125 L.Ed.2d 407 (1993), rev'g and remanding, 970 F.2d 487 (8th Cir.1992), rev'g 756 F.Supp. St. Mary’s Honor Center v. Hicks The St. Mary’s Center v. Hicks case created national storm after the Supreme Court decision that an employee must provide evidence and prove discrimination in the workplace. 92-602. Melvin Hicks, Appellant, v. St. Mary's Honor Center, Division of Adult Institutions Ofthe Department of Corrections and Human Resourcesof the State of Missouri; Steve Long, Appellees, 2 F.3d 265 (8th Cir. officer and later a shift commander. against him, id., at 254, requiring judgment in his favor unless Pp. proving that the adverse actions were racially motivated. Due to the complaints of the condition of the facility by the state and inmates, Saint Mary's conducted an undercover investigation (Cundiff, & Chaitovitz, 1994). DuPont de Nemours and Co. Respondent Hicks . 1244 (E.D.Mo.1991). For example, the Court twice states that the plaintiff must show "both that the reason was false, and that discrimination was the real reason." Brewer v. Quaker State Oil Riifining Co. The Court thus transforms the employer's burden of production from a device used to provide notice and promote fairness into a misleading and potentially useless ritual. Advocates. v. Hicks, 113 S. Ct. 2742, 2757 (1993) (Souter, J., dissenting) (stating that "[tihe language of Title VII . discrimination; that petitioners had rebutted that presumption by Aikens, 460 U.S. 711, 714. He would have held that in Title VII employment discrimination cases, proof of a prima facie case not only raised an inference of discrimination, but also, in the absence of further evidence, created a mandatory presumption in favor of the plaintiff. 1991). which, if believed by the trier of fact, would support a finding that He said the majority's approach was "inexplicable in forgiving employers who present false evidence in court". Lower court United States Court of Appeals for the Eighth Circuit . aside this determination, the Court of Appeals held that Hicks was St. Mary's Honor Center v. Hicks, 509 U.S. 502 (1993), was a US labor law case before the United States Supreme Court on the burden of proof and the relevance of intent for race discrimination. Petitioner halfway house employed respondent Hicks as a correctional Advocates. The decision de- This presumption 92-602, St. Mary’s Honor Center v. Melvin Hicks. Respondent Melvin Hicks, a black man, was hired as a correctional officer at St. Mary's in August 1978 and was promoted to shift commander, one of six supervisory positions, in February 1980. He said the following: The Court today decides to abandon the settled law that sets out this structure for trying disparate-treatment Title VII cases, only to adopt a scheme that will be unfair to plaintiffs, unworkable in practice, and inexplicable in forgiving employers who present false evidence in court. MARK . Respondent Hicks . Id. Melvin Hicks, an African American, was discharged from his job as a shift commander at St. Mary's Honor Center correctional facility, allegedly because of numerous deficiencies in his job performance, including threatening his immediate supervisor, John Powell, during a 92-602. St. Mary's Honor Center v. Hicks 113 S. Ct. 2742 (1993) Justice Scalia delivered the opinion of the Court. U.S. Reports: St. Mary's Honor Ctr. 1991). The Note begins with a brief review of the case law governing the burden of proof and then outlines the facts and procedural history of the Hicks case, including both the majority and dissenting opinions. St. Mary's Honor Center v. Hicks: The Title VII Shifting Burden Stays Put [T]he question facing triers of fact in discrimination cases is both sensitive and difficult. v. Hicks' is a Title VIW2 discharge case which, at first blush, seems to severely limit the framework set out in McDonnell Douglas Corp. v. Green3 for proving unlawful discrimina- … Discrediting the reasons offered by the employer for its decision no longer suffices to establish a violation of Title VII. [2], The United States Court of Appeals for the Eighth Circuit reversed and remanded, holding that, once the employee had proved all of the employer's proffered reasons for the adverse employment actions to be pretextual, the employee was entitled to judgment as a matter of law. Hicks had a satisfactory employment record with the Defendant until he was assigned a new supervisor. ST. MARY’S HONOR CENTER et al. The Demise of Circumstantial Proof in Employment Discrimination Litigation: St. Mary's Honor Center v. Hicks, Pretext, and the 'Personality' Excuse January 1997 In a suit against an employer alleging intentional racial discrimination in violation of Title VII, trier of fact's rejection of employer's asserted reasons for its actions does not compel judgment for plaintiff. After a bench … Melvin Hicks appeals from a final judgment entered in the United States District Court1 for the Eastern District of Missouri in favor of his former employer, St. Mary's Honor Center (St. Mary's), and the superintendent of St. Mary's, Steve Long (together defendants), on his claims arising under Title VII and the equal protection clause. The Civil Rights Act of 1964 Petitioner halfway house employed respondent Hicks as a correctional officer and later a shift commander. St. Mary’s Honor Center introduced two legitimate pieces of evidence of nondiscriminatory reasons for Hick’s termination. In addition, in summing up its reading of our earlier cases, the Court states that "[i]t is not enough . Petitioner St. Mary's Honor Center (St. Mary's) is a halfway house operated by the Missouri Department of Corrections and Human Resources (MDCHR). ST. MARY'S HONOR CENTER V. HICKS: QUESTIONING THE BASIC ASSUMPTION Deborah A. Calloway* [Tihe prima facie case "raises an inference of discrimina-tion ... because we presume these acts, if otherwise unex- plained, are more likely than not based on the consideration of impermissible factors."' Prima Facie is a legal claim that has sufficient evidence to proceed to trial or judgment. rebutted the presumption of intentional discrimination. 2-9. Evid. Citation 509 US 502 (1993) Argued. will produce dire practical consequences are unfounded. v. Hicks Call Number/Physical Location Call Number: KF101 St. Mary's Honor Center v. Hicks. St. Mary's Honor Center V. Melvin Hicks (Docket No. being done in connection with this case, at the time the opinion is issued. In Latin, prima facie means “at first sight” or “at first view”. its actions does not entitle a plaintiff to judgment as a matter of law. 450 U.S., at 256, 10 S.Ct., at 1095; see Aikens, supra, at 716, 103 S.Ct., at 1482; id., at 717-718, 103 S.Ct., at 1482-1483 (BLACKMUN, J., joined by Brennan, J., concurring). Hick is Black-American and a satisfactory employment history. The syllabus constitutes no part of the opinion of the Court but has been In setting 1244, 1252 (E.D. Lower court United States Court of Appeals for the Eighth Circuit . Melvin Hicks appeals from a final judgment entered in the United States District Court 1 for the Eastern District of Missouri in favor of his former employer, St. Mary's Honor Center (St. Mary's), and the superintendent of St. Mary's, Steve Long (together defendants), on his claims arising under Title VII and the equal protection clause. CASE ANALYSIS: (1993) ST. MARY’S HONOR CENTER V. HICKS 3 The reasons didn’t have to necessarily be persuasive, they just had to be able support the idea of intentional discrimination. 1996] EMPLOYMENT lAW-RAMIFICATIONS OF Sr. M4Ry:S HONOR CENTER v..HICKS: THE THIRD CIRCUIT' S REVIVAL OF THE "PRETEXT-ONLY" STANDARD AT SUMMARY JUDGMENT Sheridan v. E.I. 1244 — Brought to you by Free Law Project, a non-profit dedicated to creating high quality open legal information. Hicks v. St. Mary's Honor Ctr., 2 F.3d 265 (8th Cir.1993) (amended by substitution on Feb. 15, 1994) (Hicks IV ). 1992), rev'g 756 F. Supp. 92-602 . In St. Mary's Honor Center v. Hicks, a closely-divided Supreme Court substantially altered the McDonnell Douglas framework. St. Mary's Honor Center v. Hicks, 509 U.S. 502 (1993), was a US labor law case before the United States Supreme Court on the burden of proof and the relevance of intent for race discrimination. For the reasons discussed below, we remand the case to the district court for further consideration in light of the Supreme Court's opinion. McDonnell Douglas framework then became irrelevant, and the trier 9-17. preponderance of the evidence, a prima facie case of discrimination, St. Mary’s Honor Center v. Hicks, 509 U.S. 502 (1993) The Defendant was a halfway house that employed the Plaintiff, Hicks, as a correctional officer. There will seldom be 'eyewitness' testimony as to the employer's mental processes. 92-602 . Respondent Hicks . To demonstrate discrimination, an employee must conform under Title VII of the Civil Rights Act of 1964 (Cundiff, & Chaitovitz, 1994). Argued April 20, 1993-- Decided June 25, 1993. Hicks, who was a black employee of St Mary's Honor Center, a halfway house operated by the Missouri department of corrections and human resources, claimed race discrimination when he was demoted and discharged under the Civil Rights Act of 1964 §2000e-2(a)(1). Decided by Rehnquist Court . While the Court appears to acknowledge that a plaintiff will have the task of disproving even vaguely suggested reasons, and while it recognizes the need for "[c]larity regarding the requisite elements of proof," ante, at ____, it nonetheless gives conflicting signals about the scope of its holding in this case. 2 McDonnell Douglas established a tripartite burden-shifting analysis for proving intentional discrimination by the employer, that is, for proving disparate treatment, in those cases where no direct evidence of liability is available. Apr 20, 1993. a presumption arose that petitioners unlawfully discriminated St. Mary's Honor Center v. Hicks, --- U.S. ----, 113 S. Ct. 2742, 125 L. Ed. Pp. preponderance of the evidence, a prima facie case of racial We’ll hear argument next in No. Melvin Hicks appeals from a final judgment entered in the United States District Court1 for the Eastern District of Missouri in favor of his former employer, St. Mary's Honor Center (St. Mary's), and the superintendent of St. Mary's, Steve Long (together defendants), on his claims arising under Title VII and the equal protection clause. 1244 (E.D.Mo.1991). entitled to judgment as a matter of law once he proved that all of v. Hicks, 113 S. Ct. 2742, 2745 (1993). 92–602. We have repeatedly identified the compelling reason for limiting the factual issues in the final stage of a McDonnell Douglas case as "the requirement that the plaintiff be afforded a full and fair opportunity to demonstrate pretext." The Supreme Court's decision in St. Mary's Honor Center v. Hicks. Three years later a state mandated examination was conducted which brought about broad authoritative modifications the … was established in McDonnell Douglas Corp. v. Green, 411 U.S. 792, St. Mary's Honor Center v. Hicks, --- U.S. ----, 113 S.Ct. 82 Hicks v. St. Mary's Honor Center, 756 F. Supp. petitioners' proffered reasons were pretextual. [1] He brought an action, in the United States District Court for the Eastern District of Missouri. Rule that the basis for [the] discriminatory treatment was race ") (emphasis in original). Lower court United States Court of Appeals for the Eighth Circuit . Saint Mary's Center is a correctional facility. Decided . with Hicks, id., at 253. Adhering to the Oral Argument - April 20, 1993; Opinions. Discrediting the reasons offered by the employer for its decision No longer suffices establish... 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