Case Analysis: (1993) St. Mary's Honor Center v. Hicks
“No lawsuit can be decided, rationally, without the application of the commonplace concept of burden of proof – the duty to persuade – or as is sometimes otherwise stated the risk of non-persuasion” (McBaine, 1944, p. 242). In the case St. Mary’s Honor Center, et al., Petitioners v. Melvin Hicks (Hicks), the burden of proof was a point of contention throughout the case’s development; from the initial hearing in the United States District Court for the Eastern District of Missouri (District Court) to the final hearing in the Supreme Court of the United States (Supreme Court). In the argument of a Title VII of the Civil Rights Act of 1964 (Title VII) case, the burden of proof of discriminatory acts remains with the plaintiff throughout the case.
Case Summary
In 1978, Mr. Melvin Hicks was hired by a halfway house in Missouri, St. Mary’s Honor Center (St. Mary’s). From 1978 to 1984, Mr. Hicks received satisfactory employee evaluations from his immediate supervisor and were approved by the superintendent of the facility (Reed & Bogardus, 2012). In 1980, Melvin Hicks was promoted to a shift commander, which equates to one of the six immediate supervisors at St. Mary’s (Cornell University Law School, 1993a). Following an investigation, Mr. Hicks’ supervisor and the
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superintendent of St. Mary’s were both replaced in January of 1984 (Reed & Bogardus, 2012). Shortly following supervisory changes, Mr. Hicks began receiving disciplinary actions for his lack of supervisory oversight that led to his demotion. Examples of Melvin Hicks’ punitive measures include: • A five-day suspension for his subordinates’ rules violations. • A letter of reprimand for not completing a proper investigation of a fight between inmates (Cornell University Law School, 1993a). • His demotion because his subordinates did not log their company vehicle usage in the vehicle log (Cornell University Law School, 1993a). • During a heated argument, Melvin Hicks threatened his supervisor, which ultimately led to his termination at St. Mary’s in June of 1984 (Reed & Bogardus, 2012). On account of Mr. Hicks’ protected class and the actions leading to his dismissal, Melvin Hicks filed a Title VII case against St. Mary’s with the District Court. Mr. Hicks “satisfied the requirements for a prima facie case” by: 1. Stating he was black, 2. Proving he was qualified for his supervisory role, 3. Attesting he was demoted and later terminated, and 4. Confirming the position was filled by a white, male after remaining open for some time (Cornell University Law School, 1993a, para. 9). Since Mr. Hicks was able to prove his prima facie violation, St. Mary’s (the defendant) had to provide evidence the unfavorable actions were consequences of legitimate, lawful reasons and not discriminatory motives. St. Mary’s provided the documentation of the disciplinary actions taken against Mr. Hicks during his tenure at the halfway house. At this time, it was Melvin Hicks’ responsibility to provide evidence the punitive actions were the result of his protected class and not on account of personal reasons. The District Court did not contest the different, more harsh treatment of Mr. Hicks from his counterparts (Cornell University Law School, 1993a). Nor did the court deny the disciplinary actions and discharge were not for the reasons given by the defendant. At the same time, Mr. Hicks (the plaintiff) lacked preponderance of evidence proving racial motives behind the unfavorable actions (Cornell University Law School, 1993a). Therefore, the District Court did not rule in favor for Mr. Hicks. The District Court defended the ruling by explaining the board is wiped clean after the plaintiff proves a prima facie violation and the defendant retorts with nondiscriminatory explanations for the actions (Cornell University Law School, 1993a). Following the retort the plaintiff must provide new evidence proving the motives were racial, wherein the plaintiff did not. The United States Court of Appeals for the Eighth Circuit (Court of Appeals) heard the case where the District Court’s verdict was overturned and ruled in favor of the plaintiff.
The Court of Appeals did not agree with the District Court’s reasoning that once the defendant provides proof the plaintiff must provide new evidence. Instead, the Court of Appeals explains the defendant did not prove the actions were nondiscriminatory once the rebuttal was noted as a front for the plaintiff’s termination (Cornell University Law School, 1993a). In summary, the defendant lost the case because they could not prove the motives were
nondiscriminatory. The case was taken to the Supreme Court where the justices split their decisions based on their interpretations of three previous cases: McDonnell Douglas Corp. v. Green (Green), Texas Dept. of Community Affairs v. Burdine (Burdine), and USPS Bd. of Governors v. Aikens (Aikens). The majority sided with the defendant on the reasoning the plaintiff did not provide evidence of discrimination. The Supreme Court clarified retraction of evidence is exempt when the evidence shows the disparate act is not in response to discrimination (Cornell University Law School, 1993a). Case Questions Three questions surface from St. Mary’s v. Hicks: 1. Did the plaintiff prove a prima facie violation by standards set in the Green case? Yes. 2. Did the defendant provide substantiating, nondiscriminatory evidence against the plaintiff by standards set in the Burdine and then again in the Aikens case? Yes and no. First, nondiscriminatory evidence was submitted. Nevertheless, the District Court judges were not 100% convinced a pretext did not exist prior to issuing the disciplinary actions. Second, the Court of Appeals stated the defendant did not provide nondiscriminatory evidence since the motives behind the evidence were not reliable. 3. Did the plaintiff rebut the defendant’s evidence by establishing a discrimination pretext to the defendant’s motives? No, and yes. The Supreme Court majority ordered the plaintiff did not provide evidence establishing a discrimination pretext to the defendant’s motives. Consistent with the Green case, when the plaintiff does not show pretext to the employer’s actions then the employment action is legal (Cornell University Law School, 1993a). Yet, Justice Souter’s dissent reads, “Thus, because Hicks carried his burden of persuasion by showing that St. Mary’s proffered reasons were “unworthy of credence,” the Court of Appeals properly concluded that he was entitled to judgment” (Cornell University Law School, 1993b, para. 9).
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