Atlanta Employment Attorneys Blog
Last year, a few major U.S. Supreme Court rulings turned 50 years old. The first case to come to many minds probably is the landmark 1973 ruling of Roe v. Wade. However, the name at the tips of employment lawyers’ tongues probably is the discrimination case of McDonnell Douglas Corp. v. Green. Recently, the 11th Circuit Court of Appeals (whose reach encompasses federal matters in Georgia, Florida, and Alabama,) issued a significant decision clarifying exactly how the McDonnell Douglas case’s precedent does — and does not — impact discrimination litigation today. If you have questions about employment discrimination, you need to consult a knowledgeable Atlanta employment discrimination lawyer who can provide you with information that is fully up to date.
The recent discrimination case, decided in December, involved L.T., an African-American woman and the superintendent of a juvenile detention center, and her employer, the Florida Department of Juvenile Justice. After one particularly problematic day at the center, the assistant secretary of detention services assembled a team to review staffing and personnel issues at L.T.’s facility. After the team completed that review, the assistant secretary fired L.T., despite the superintendent’s 16-year record devoid of negative performance reviews or discipline.
The superintendent sued for race and sex discrimination. A key part of her case was comparator evidence; namely, that two similarly situated white Juvenile Justice employees had faced similar problems but were treated very differently. The department immediately fired L.T.; the two white superintendents who similarly faced allegations of a lack of control and a failure to follow departmental policies “received only oral reprimands, were allowed to transfer to different facilities, and were granted multiple opportunities to comply with various recommendations for improvement.”
The superintendent’s case persuaded the jury, who returned a judgment in her favor and awarded her more than $900,000 in damages.
The Elements of a ‘Prima Facie Case’ of Discrimination
The department appealed, arguing that the law demanded a judgment in its favor because L.T. had not satisfied what the McDonnell Douglas case requires. The Supreme Court’s ruling in McDonnell Douglas established a framework for analyzing circumstantial cases of employment discrimination. The framework places the initial burden of proof on the worker to make out a “prima facie case.” The elements of that burden demand that the worker demonstrate that:
- “she belongs to a protected class,”
- “she was subjected to an adverse employment action,”
- “she was qualified to perform the job in question,” and
- “her employer treated ‘similarly situated’ employees outside her class more favorably.”
The center of the department’s argument was that the two white superintendents L.T. used as comparators were not “similarly situated in all material aspects,” meaning she had fallen short of meeting the “prima facie case” requirement.
The McDonnell Douglas Framework: One Way But Not the Only Way
The court rejected the employer’s position, stating that satisfying the elements of the McDonnell Douglas framework is a means — but not the sole means — by which a worker can win a discrimination case. As the court further explained, a worker “who cannot satisfy this framework may still be able to prove her case with what we have sometimes called a ‘convincing mosaic of circumstantial evidence that would allow a jury to infer intentional discrimination by the decisionmaker.'”
In L.T.’s case, even in the absence of satisfying the McDonnell Douglas framework elements, she presented adequate evidence at trial from which a reasonable jury could draw the conclusion that the employer’s decision to fire her was rooted in discrimination, so the appeals court upheld the judgment and award in her favor.
The practical impacts of L.T.’s case are not yet fully known, but it is a clear reminder that employees have multiple pathways to success in employment discrimination actions. Whether you’re a worker harmed by impermissible discrimination or an employer facing such a claim, you can enhance your odds of a positive outcome by retaining skilled legal counsel. Rely on the experienced Atlanta race discrimination attorneys at the law firm of Parks, Chesin & Walbert to be that skilled and effective legal advocate in your corner, providing you with the advice and advocacy you need for success. Contact us today at 404-873-8048 or through this website to schedule a consultation.