Question

I would like some help rewording this IRAC analysis..

Issue: The issue at hand with this case is whether or not the Court of Appeals properly reversed the dismissal of the plaintiff employees 703(a)(1) claim.

Rule: The complainant in a trial under Title VII of the Civil Rights Act of 1964 carries the initial burden under the statute of establishing a prima facie case of racial discrimination. This may be done by showing (i) that he belongs to a racial minority; (ii) that he applied and was qualified for a job for which the employer was seeking applicants; (iii) that, despite his qualifications, he was rejected; and (iv) that, after his rejection, the position remained open and the employer continued to seek applicants from persons of complainant's qualifications. The burden then shifts to the employer to articulate some legitimate, nondiscriminatory reason for the employee's rejection.

Analysis: Green, who was employed as a mechanic by McDonnell Douglas Corp., was laid off in the course of a general reduction in the McDonnell Douglas Corp.'s work force. Green, who is African american, participated in a protest against alleged racial discrimination by McDonnell Douglas Corp. in its employment practices. The protest included a "stall-in" whereby Green and others stopped their cars along roads leading to the McDonnell Douglas Corp.'s plant, so as to block access to the plant during the morning rush hour. When the defendant subsequently advertised for mechanics, Green applied for reemployment, but McDonnell Douglas Corp. rejected him on the asserted ground of his participation in the "stall-in." Green then filed a complaint with the Equal Employment Opportunity Commission, claiming that the defendant had violated 703(a)(1) of the Civil Rights Act by refusing to rehire him because of his race, and that McDonnell Douglas Corp. had violated 704(a) of the Act by refusing to rehire him because of his activities in protesting against racial discrimination. The Commission made no finding on Green's 703(a)(1) claim but found reasonable cause to believe that McDonnell Douglas Corp. had violated 704(a). After the Commission unsuccessfully attempted conciliation, Green asserted his 703(a)(1) and 704(a) claims in the United States District Court. The District Court dismissed the 703(a)(1) claim on the ground that the Commission had failed to make a determination of reasonable cause to believe that the defendant had violated 703(a)(1). After a trial, the District Court dismissed the 704(a) claim with prejudice, on the ground that the McDonnell Douglas Corp.'s refusal to rehire Green was based on the Green's conduct during the "stall-in," which conduct was illegal and was unprotected by 704(a). The Court of Appeals for the Eighth Circuit affirmed the dismissal of the 704(a) claim, but the Court of Appeals held that a prior Commission determination of reasonable cause was not a jurisdictional prerequisite to raising a 703(a)(1) claim in federal court, and the Court of Appeals reversed the dismissal of the 703(a)(1) claim and set forth standards as to the parties' burden of proof, upon remand, with respect to the 703(a)(1) claim.

Conclusion: The Supreme Court of the United States vacated the appellate judgment. The Court affirmed the reversal of the dismissal of the § 703(a)(1) claim because an Equal Employment Opportunity Commission finding of reasonable cause was not a jurisdictional prerequisite to the employee's federal action for violation of § 703(a)(1). In remanding the matter for trial, the Court instructed the lower court on the order and allocation of proof for the employee's claim. The Court found that the employee had presented a prima facie case of racial discrimination under § 703(a)(1) by showing that he was rejected for a job for which the employer knew he was qualified. However, the employer offered a legitimate, nondiscriminatory reason for the employee's rejection in his participation in unlawful conduct against it. Therefore, the employee was entitled to a fair opportunity at trial to show that the employer used his conduct as a pretext for racial discrimination.

Answer 1

Issue :

The case reflects on the issue of determining if the court of Appeals reversed the dismissal of plaintiff employees 703 (a)(1) claim or not.

Rule :

Under the Title VII of the civil rights act of 1964 , the complainant carries the burden for establishing a prima facia discrimination case under the statute. The various factors which include i) the person is from the minority race ii) the person was qualified for the job after applying for the position which the employer was seeking iii) the person being eligible and qualified for job was still rejected iv) the post still remained open and invited applicants with same qualification.

The burden is then shifted to the employer who needs to provide some legitimate, authentic and non discriminatory reasons for demonstrating such behavior of rejecting employee.

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Analysis :

An employer of McDonell Douglas Corporation named Green who was working as a mechanic in the company was allegedly laid off during the reduction of company's workforce.

The employer was from an African-American descent and participated in a protest against the company for observing racial discrimination in its practices related to employment.

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The protest included stopping the cars from passing through the company's plant during morning hours by establishing stalls on the road. When the company again invited applicants for the position if mechanic , Green after applying for second time gpt rejects on the grounds of being involved in "Stall In" protest. Green after this filed a complaint under EEOC and claimed that the defended(company) has violated the section 703(a)(1) of Civil rights act and demonstrated his rejection as the reason if his race and his participation in protest for his right. There was no finding made on his claim under 703(a)(1) but the defended was found violating the 704(a) portion of law. The commission afterwards attempted for conciliation which proved unsuccessful, and Green appealed the case under 703(a)(1) and 704(a) in District Court of US with the assertion that coommission has failed to recognise the case as reasonable to hold the defendant guilty under 703(a)(1).

The district court after the trial dismissed the 704(a) claim based on the grounds that McDonnell Douglas has refused to hire Green on the basis of his illegal conduct and not protected under 704(a). The Court of Appeals for 8th circuit affirmed the dismissal of 704(a) claim however it also held that raising a 703(a)(1) claim in the federal court for prior commision determination of reasonable cause was not jurisdictional prerequisite.Thusthe court of Appeal reversed the dismissal of 703(a)(1) claim and established certain standards for the parties")' burden of proof , upon remand to respect 703(a)(1) claim.

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Conclusion :

The appallate judgement was vacated by the US Supreme Court. The reversal of dismissal of 703(a)(1) claim was affirmed by the court because EEOC findings of reasonable cause was not prerequisite of jurisdiction to the federal action taken by employee for violation of 703(a)(1).

During trial , the lower court was instructed on the order and allocation of proof for claim made by employee. It was found that the employee had presented a prima facial case for discrimination against race by demonstrating his rejection for application for which he was qualified.

But Employer on the other hand presented a authentic and legitimate non discriminatory reason for rejection in participation of unlawful conduct against it. Thus employer was entitled to a fair opportunity during the trial to present the case to show employer using his conduct as a cause of racial discrimination.

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Thanks dear student.. Hope this helps..

Please note that wording has changed but the meaning is same

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