The U.S. Supreme Court on Monday declined to revisit a pivotal test established in the 1970s for proving workplace discrimination under Title VII of the Civil Rights Act.
The Court rejected a petition by Ronald Hittle, a former fire chief from Stockton, California, challenging the 9th U.S. Circuit Court of Appeals’ decision that ruled he failed to prove he was fired due to his religion.
The framework in question, stemming from the 1973 Supreme Court case McDonnell Douglas v. Green, is frequently applied in discrimination cases that rely on circumstantial evidence.
It allows employers to present legitimate, nondiscriminatory reasons for an employment decision, which shifts the burden to the plaintiff to prove those reasons are pretexts for discrimination.
While appeals courts are not required to use the McDonnell Douglas standard, they often do, leading to complex and conflicting legal precedents.
In particular, there is disagreement among courts regarding whether plaintiffs must disprove an employer’s reasons or only show other evidence of discrimination.
Hittle’s case, which centered on his claim that he was fired for attending a Christian leadership conference while on duty, was dismissed by the 9th Circuit.
The court upheld the summary judgment in favor of the city, stating that Hittle failed to prove the city’s reasons for termination were discriminatory.
Justices Clarence Thomas and Neil Gorsuch dissented from the decision, arguing that the McDonnell Douglas framework had caused substantial confusion in the courts and should not be treated as a strict legal standard.
Thomas, in particular, emphasized that a Title VII claim should survive summary judgment if the plaintiff raises a genuine dispute of material fact about each element of the claim.
The case is Hittle v. Stockton, California, U.S. Supreme Court, No. 24-427.
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