[10], The court stopped short of saying that a court must assume discrimination where a nondiscriminatory reason is shown to be false. 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 (ADEA), alleging that his discharge from Sanderson was impermissibly based on his age. Reeves v. Sanderson Plumbing Prods. of Community Affairs v. Burdine, https://en.wikipedia.org/w/index.php?title=Reeves_v._Sanderson_Plumbing_Products,_Inc.&oldid=906774230, United States employment discrimination case law, United States Supreme Court cases of the Rehnquist Court, Creative Commons Attribution-ShareAlike License, This page was last edited on 18 July 2019, at 04:30. Weinstock v. Columbia Univ., 99-7979 (2 nd Cir. 197 F.3d 688, 690 (CA5 1999). The Fifth Circuit went on to discount remarks made by professors on the promotion and pay raise committees. This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. REEVES v. SANDERSON PLUMBING PRODUCTS, INC. CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT No. Initially, the Reeves decision was seen as a victory for employment plaintiffs. 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. The district court granted summary judgment to Davis on all three claims. The trier of fact may reasonably find for the employer where the plaintiff makes only a weak showing of evidence as to the untruth of the employer's defense, or where there is ample evidence of another nondiscriminatory reason that the employer did not offer. At the time of his discharge, Reeves worked in a department of the company known as the Hinge Room. Learn more about FindLaw’s newsletters, including our terms of use and privacy policy. It is especially interesting to see how the Fifth Circuit will react to the Reeves decision as it was the Fifth Circuit that the Supreme Court unanimously overturned. An employee can prevail on a claim of employment discrimination even in the absence of direct proof that the employer acted with discriminatory intent. Reeves v. Sanderson, 530 U.S. 133 (2000) Workplace Equality and Economic Empowerment; Year: 2000. Fifty-seven year old Reeves was employed for 40 years by Sanderson — a company involved in the manufacture of toilet seats and covers. Argued March 21, 2000-Decided June 12,2000. 2097, 2110 (June 12, 2000). Ct. ___ (2000), may apply to all discrimination cases, and not just those under the Age Discrimination in Employment Act (ADEA). Seemingly, the singular truth about Reeves is that only time will tell its significance. On June 12, 2000, the United States Supreme Court issued the decision of Reeves v. Sanderson Plumbing Inc., U.S., 120 S.Ct. Inc., 913 F.2d 253, 256 (5th Cir. Tulane offered as its legitimate nondiscriminatory reason the fact that Rubinstein was a poor teacher, that the University lacked funds to give raises to every professor, and that Rubinstein was a poor university citizen, as evidenced by his lack of participation on committees. [3], The Fifth Circuit Court of Appeals reversed, saying that Reeves did not provide enough evidence to prove that his age was the cause of the employment decision in question. Hence, we reverse the district court's order and render judgment in favor of Sanderson. ultimate employment decision. Copyright © 2020, Thomson Reuters. Ct. ___ (2000), may apply to all discrimination cases, and not just those under the Age Discrimination in Employment Act (ADEA). ii PARTIES TO THE PROCEEDING Sandra Day O’Connor: VII. Based upon the evidence listed above and the fact that appellants had also produced direct evidence of discrimination, the Court of Appeals reversed the granting of summary judgment. Chesnut investigated briefly, and determined that Reeves, Oswalt, and Caldwell had all made errors in tracking time worked by their employees. Stay up-to-date with FindLaw's newsletter for legal professionals, Reeves v. Sanderson Plumbing Products, Inc.: What Impact Will It Have? 1990); see also Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133, 147, 120 S. Ct. 2097, 2108 (2000) (“In appropriate circumstances, the trier of fact can reasonably infer from the falsity of [an] explanation that the employer is dissembling to cover up a … Argued March 21, 2000—Decided June 12, 2000 Petitioner Reeves, 57, and Joe Oswalt, in his mid-30’ s, were the super-visors in one of respondent’ s departments known as the “Hinge [1], In June 1996, Reeves sued in the United States District Court for the Northern District of Mississippi under the Age Discrimination in Employment Act. The district court granted summary judgment and the plaintiff appealed. In 1995, 57-year-old Roger Reeves and Joe Oswalt, who was in his mid-thirties, were supervisors at Sanderson Plumbing Products, being managed by 45-year-old Russell Caldwell. REEVES v. SANDERSON PLUMBING PRODUCTS, INC. CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT. Maybe None. 99-536. § 284 is collateral to, and therefore not a merits ruling necessary for final judgment under this Court’s reasoning in Budinich v. ... redibility determinations,” contrary to Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133, 150-51 (2000). Moreover, in Reeves v. Sanderson Plumbing Products, Inc. (2000) 530 U.S. 133, 151-152 [147 L. Ed. She stated that such cases will be rare, because a dishonest defendant may be assumed to have some level of culpability, based on a fundamental principle of evidence law.[13]. She determined that respondent had not been entitled to a judgment as a matter of law, both because there was a question of fact to be decided by a jury in evaluating the truth of the defendant's nondiscriminatory explanation, and because the court of appeals should have reviewed the entire record in a manner favorable to the nonmoving party, which in this case was Reeves. 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. Caldwell reported a drop in production in the summer of 1995 to the director of manufacturing, Powe Chesnut, who was also married to the president of the company, Sandra Sanderson. Her first task was to set out the context of the case, starting with explaining that she would assume that McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973), was the relevant standard for analyzing a case brought under the ADEA, because nobody had disputed that fact, even though the court had never addressed that issue before. Caldwell informed the company's director of … In 1995, 57-year-old Roger Reeves and Joe Oswalt, who was in his mid-thirties, were supervisors at Sanderson Plumbing Products, being managed by 45-year-old Russell Caldwell. [11], After determining that the trial court could have found in favor of Reeves, O'Connor turned to examining the procedural questions at hand. Specifically, the professors had stated that Rubinstein was a "Russian Yankee", that Jews were thrifty and that if the Russian Jew could obtain tenure, then anyone could. In this age discrimination case, Reeves alleged that the manager who fired him told him he was "too damn old." A recent Supreme Court decision, Reeves v. Sanderson Plumbing Products, 120 S. Ct. 2097 (2000), resolved an important disagreement among the lower federal courts over the legal standards which will govern an employer’s motion for summary judgment. To establish pretext, Weinstock relied on three points: (1) gender stereotyping existed at the University; (2) there were irregularities in the ad hoc committee process, (3) she was treated differently than similarly situated males. [13], She also wrote separately to note that future cases may require the court to examine exactly which circumstances may give rise to the plaintiff being required to provide further evidence. In Chuang , plaintiffs, Dr. Ronald Y. Chuang and Dr. Linda Chuang, contended that officials at the University of California, Davis discriminated against them on the basis of their race (Asian) and national origin (Chinese) in violation of Title VII. However, in agreeing to review the case, the Supreme Court considered the general conflict among the federal courts over the kind and amount of evidence necessary to prove intentional discrimination. at 2109. With the release of this opinion, many thought that a plaintiff's burden of proof had been lifted somewhat, the full … Dismissing appellant's points, the Court of Appeals held that she had not produced sufficient evidence to establish pretext. 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