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St. Mary’s Honor Center v. Hicks | 509 U.S. 502 (1993)
In St. Mary’s Honor Center versus Hicks, the United States Supreme Court explored the nuances of the burdens of proof and persuasion in a Title VII racial-discrimination case.
Melvin Hicks, a black man, had worked for several years as a correctional officer at Saint Mary’s Honor Center, a halfway house operated by the Missouri Department of Corrections. His performance evaluations were satisfactory until Saint Mary’s hired a new chief of custody and a new superintendent. Shortly thereafter, Hicks started getting in trouble for violating rules. He was suspended for five days, reprimanded, and demoted. Finally, he was fired after threatening the chief of custody during an argument.
Hicks sued St. Mary’s, alleging that he’d been demoted and discharged because of his race in violation of Title Seven of the Civil Rights Act of 1964. The district court found that Hicks had established a prima facie case of racial discrimination, but Saint Mary’s had rebutted it by showing legitimate, nondiscriminatory reasons for its actions. The court then found that Saint Mary’s reasons weren’t credible, but Hicks nevertheless had failed to prove that race was the determining factor for his discharge.
The Eighth Circuit reversed. It held that once Hicks had proven that Saint Mary’s reasons were pretexts for discrimination, he was entitled to judgment as a matter of law.
The United States Supreme Court granted cert.
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