McDonnell-Douglas v. Green
Legal Issues
The Facts
Percy Green, a Black civil rights activist, was laid off by McDonnell Douglas and later rejected when he reapplied. He alleged the rejection was racially motivated. The district court dismissed for lack of direct evidence of discrimination. The Eighth Circuit reversed, and the Supreme Court granted certiorari to establish the proper evidentiary framework.
The Issue
What evidentiary framework applies in Title VII disparate treatment cases lacking direct evidence of discrimination
The Rules
Title VII of the Civil Rights Act of 1964 — disparate treatment
McDonnell Douglas burden-shifting framework
Pretext analysis
The Application
Green's claim exemplified the need for the framework: lacking direct evidence of discriminatory intent, he could still establish discrimination through a prima facie showing of his qualifications and rejection. McDonnell Douglas articulated a legitimate, nondiscriminatory reason for its refusal—Green's earlier participation in illegal protest activities—requiring Green to then prove the stated reason was pretextual and race was the true motive. The Court thus held that Title VII plaintiffs need not present direct proof of discrimination but instead can succeed through the structured burden-shifting analysis, establishing a framework that immediately became the standard for evaluating individual disparate treatment claims.
The Conclusion
Court unanimously established the prima facie case → legitimate reason → pretext framework. McDonnell Douglas remains foundational employment discrimination law.
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