Case Analysis (1993) St. Mary`s Honor Center v. Hicks


CaseAnalysis: (1993) St. Mary’s Honor Center v. Hicks

CaseAnalysis: (1993) St. Mary’s Honor Center v. Hicks


TheAct of Civil Rights was apprehended to guard the civil rightspopulaces and give them relief whenever they are violated. TheLegislative body assented to the Civil Rights Act mainly due to theracial-based concerns. When drafting the bill, the House JudiciaryCommittee realized that though many constitutional provisionsguaranteed equal treatment of every citizen, genuine equality wasstill a problem. The existing acts did not ensure true equality.Therefore, Congress instituted the laws to curb the ever increasingemployment discriminations. The work field was quite troublesome dueto the inequalities involved. Congress then developed the ‘EqualEmployment Opportunity Commission (EEOC)’ to eradicate illegal workactivities through formal and informal means. Moreover, theCommission was vested with the principal duty of avoiding andeliminating occupation practices which violated Title VII [CITATION Deb94 l 1033 ].

Eventhough the Title VII Act was intended to eliminate discriminatoryemployment activities, it did not give the courts or EEOC appropriatestandards to evaluate and adjudicate allegations of discriminations.The lack of guidance appeared to be detrimental. The House JudiciaryCommittee members of the minority warned that the enactment of thatlaw would require the employers to prove their innocence.

of the Case

Thecase in consideration involved a black worker at the halfway houseran by the Missouri constituent part of human resources andcorrections. The employee, Hicks, brought a suit under ‘703 (a) (1)of Title VII of the Civil Rights Act of 1964 (42USCS 2000e-2 (a)(1))’ claiming that the facility had contravened the Act bydemoting and subsequently firing the employee based on his race. Thecorrectional facility was situated in St. Louis, Missouri andconstituted of five brick constructions erected between 1887 and1946. The facility functioned for a long period as a hospital,detoxification center, rehab home, quasi-legal nursing home, andhalfway house. It was later abandoned due to a rotting roof andpartial collapse of the wall. The deterioration mandated the buildingcommissioner to issue a demolition order imminently (St. Mary’sHonor Center v. Hicks, 1993).

Atfirst, the facility employed Hicks as the officer of correction inthe year 1978. He was later endorsed to work as a shift commander in1980. During this period, the supervisors deemed Mr. Hicks’performance as satisfactory and hence the reason for promotion. Aninvestigation by MDCHR of the facility resulted in the replacement ofthe superintendent and Mr. Hicks immediate supervisor in 1984.Matters began to change after the inception of the new team. Mr.Hicks was then solely picked for disciplinary actions, and none ofhis colleagues were laid open to the same. The supervisors appearedto favor his peers, even in serious violations. At some point, Hickswas suspended and demoted from his position. He was later dischargedfrom his duties after apparently threatening the supervisor during anargument (St. Mary’s Honor Center v. Hicks,1993).

Themanner in which events unfolded forced Mr. Hicks to file a lawsuit,claiming racial discrimination. He managed to prove to the DistrictCourt that a prima facie case occurred. On the other hand, St. Mary’sgave the subsequent evidence legitimizing its actions. According tothe facility, the actions it took were completely nondiscriminatory.The burden was then shifted to Hicks to display how the actions werefalsified to hide the racial agenda of the facility. According to theDistrict Court, neither party provided substantial information. Inother words, the institution’s reasons could not be substantiated.However, Mr. Hicks did not submit enough evidence to prove that hisdischarge was racially driven. The Court stated that the availableevidence could not verify whether racism or personal dislike for Mr.Hicks motivated the termination. At the ‘Eighth Circuit Court ofAppeals,’ the judgment favored Mr. Hicks. According to the court,Mr. Hicks had proven that the explanations provided by the facilitywere a pretext (St. Mary’s Honor Center v. Hicks, 1993).

TheEighth Circuit made a mistake when it decided that the trier offact’s skepticism of the perpetrator’s given explanations placedthe respondent in a similar situation as if it had stayed mute toHicks’ prima facie claims of racial discrimination. This wasaccording to the Supreme Court. Certainly, all the respondents had todo according to the McDonnell Douglas assessment was provide evidenceof nondiscriminatory motives. The evidence did not have to bepersuasive to refute the assumption of deliberate discrimination. Theplaintiff then had to verify the crucial query of fact: that therespondent deliberately discriminated against him based on race (St.Mary’s Honor Center v. Hicks,1993).

Accordingto the high court, compelling the verdict for Hicks would disdain theultimate code that an assumption does not swing the affliction ofevidence. Also, it would disregard the caution that an applicant ofTitle VII, always, endures the ultimate burden of persuasion. TheCourt further stated that no law court might enforce burden on anyestablishment for purported prejudiced employment activities. This isunless the finder of the fact establishes that the company hasdiscriminated illegally. On the other hand, a law court maysubstitute for that prerequisite judgment the much lesser anddifferent outcome that the employer’s reason of its deed wasunbelievable (St. Mary’s Honor Center v. Hicks,1993).

Inthis event, the ‘Supreme Court’ solved the mix-up affecting thedifferent tactics to excuse. The Eighth Circuit utilized what isregarded as the &quotpretext only&quot rule, which states that oncea petitioner has proven that the perpetrator’s explanations werepretextual, he is guaranteed judgment. The Supreme Court vetoed thisrule, stating that refusal of the submitted explanations does notnecessitate judgment on behalf of the plaintiff. In addition to that,the Supreme Court overruled what is regarded as &quotpretext plus&quotmethod, which needs a verdict of judgement that the fact finder’sdoubt of the given explanations must be reinforced by a relevantproof of discernment. Additionally, the Supreme Court ruled thatsuspicion of the respondent’s offered explanations will authorizethe fact finder tried to deduce the eventual fact of deliberatediscriminations. No extra evidence of discernment is needed (St.Mary’s Honor Center v. Hicks,1993).

Certainly,the court implemented what is regarded as the &quotpermissivepretext&quot method. The strategy clarifies that, in the case wherethe trier of fact doubts the respondent’s submitted explanations,the body might make a verdict for the petitioner at that juncturewithout additional discrimination evidence. Therefore, the SupremeCourt in ‘St. Mary’s Honor Center vs. Hicks’ overturned theEighth Circuit and gave instructions consistent with its view (St.Mary’s Honor Center v. Hicks,1993).

TheDistrict Court View

TheDistrict Court, that is, Stephen N. Limbaugh Sr. acted as trier offact and established that

  1. (a) The worker found a prima facie event of discrimination of race and (b) the explanations for demotion and discharge given by the employer were not accurate, but

  2. The employee unsuccessfully provided substantial evidence that his race was the reason why he was demoted and discharged. In that regard, the court ruled on behalf of the employer.

Asthe number of African-American personnel at St.Mary’sremained calm throughout Hicks’ demotion and subsequent firing, thecourt stated that the respondent had failed to substantiate hisclaims. Apart from that, African American reviewers sat on the panelthat disciplined Hicks. According to the court, it was evident thatthe overseer had positioned Hick on the termination track.Nevertheless, it is unclear whether the respondent’s race wasutilized as the reason for the severe punishment. Definitely, thesupervisor disliked the plaintiff. Therefore, the court associateditself with the excuse approach that demanded more from the plaintiffthan an apparent case and a display of pretext. The respondent had togive direct inference or evidence to substantiate his claim of unfairtreatment [ CITATION Jod14 l 1033 ].

TheEighth Circuit View

TheCourt of Appeals reversed the ruling with a view that once thepetitioner proved that the employer provided wrong reasons fordischarging him, then judgment should be in his favor. According tothe Eighth Circuit, the lower court had erred in two conclusions.First, the court had no proof to support the notion that thesupervisor had a personal issue with the plaintiff. The respondenthad no chance to refute such a proposition. Secondly, the districtcourt incorrectly required the respondent to provide evidence ofsomething of more value than a prima pretext and facie case. However,by providing the prima facie case and pretext, the plaintiffsatisfied the eventual weight of persuasion. No extra evidence wasneeded. Under this thought, the proof of pretext and prima facie caseequaled proof of discriminatory intent. In other words, just byproofing the employer provided inaccurate information is equivalentto the discriminatory intent. Therefore, the respondent had a rightto fair judgment [ CITATION Jod14 l 1033 ].

TheSupreme Court view

JusticeScalia’s Majority View

JusticeScalia ascertained that the District Court`s refusal of the company`sstated explanations for its activities did not decree a verdict forthe worker, since

  1. Courts must not (i) treat discrimination contrarily from other definitive queries of fact, or (ii) make absolute factual assertions based on legal laws which were established to control the primary provision of burdens and directive of demonstration of proof.

  2. A verdict that the worker as substantiated by law was not authorized did not provide exceptional favor to employers whose proof refuting concerns of discrimination of race was distrusted

  3. As entailed in rule 301 on ‘Federal Rules of Evidence,’ the assumption did not change the burden of proof

  4. The ‘Supreme Court’ was not mandated to enforce obligation on a company for purported discriminatory employment activities, except if the necessary fact finder established, by the appropriate process, that the employer illegally discriminated against the employee

  5. The ‘Supreme Court’ continuously affirmed that a ‘Title VII’ plaintiff ought to bear the burden of persuading

  6. An company’s submitted explanation was unconvincing, or apparently forced, did not primarily ascertain that the worker’s explanations of race were accurate and

JusticeScouter’s Dissenting View

JusticeSouter disputed this notion. According to him, Title VII employmentdiscrimination events, proof of prima facie developed a necessaryassumption favoring the plaintiff in the deficiency of substantialevidence. It also increased the interpretation of discrimination.According to his view, the decision unfairly burdened thediscrimination victims to produce either direct evidence orabolishing the probable nondiscriminatory explanations for thestaff’s decision. If the evidence does not compel judgment for thecomplainant, then the fact finder can ascertain the reason apart fromthe one used by the facility as motivation [ CITATION Jod14 l 1033 ].

Thedissent also condemned the majority because it did not give apractical description of how a complainant having only the apparentpretext and case evidence can attain the “ultimate burden” ofevidencing discrimination. In other words, the judgment failed togive a clear illustration of the magnitude of proof a plaintiff musthave to meet the required “Ultimate burden” of proof [ CITATION Jod14 l 1033 ].

Mainissues in the case: Shifting Burden

Thecritical problem entailed upholding the Employment Act that wasagainst any discrimination. According to the Act, it was prohibitedfor a company to victimize any person based on national origin, race,sex, or religion. Under the ‘McDonnell Douglas framework’ startedin 1973, as soon as the complainant worker proves a prima faciecircumstance of discernment, the company shoulders the weight ofproducing some nondiscriminatory proof, legitimate motive for therespective practice of employment. If the company provides suchproof, the petitioner ought to prove that reasons are merely excusesfor discrimination. The means of applying the McDonnell Douglasapproach confused the lower courts. Subsequently, in 1981 and 1983,the ‘Supreme Court’ tried to elucidate the extent of theperpetrator’s burden in Title VII deliberate work discernmentjudgments. Even with the Supreme Court’s determinations, there wasa fragment within the circuits [CITATION Deb94 l 1033 ].

Theproblem revolved around the plaintiff’s entitlement to ruling as asubstance of decree if the court discards the firm’s submittednondiscriminatory motive for the adversative employment action. Inthis case, the ‘Supreme Court’ stated that the plaintiff is notentitled to the judgment even if the court discards the employer’smotives as meager excuses. Instead, the plaintiff ought tosubstantiate that the employer deliberately discriminated against thesubject. Apparently, the issues that followed were previouslymentioned by the minority members of the House Judiciary Committee.Since ‘McDonnell Douglas,’ the Law Court has regularly declinedto implore the employer to provide substantial evidence to proveinnocence. Instead, the accuser has the vital duty of providingevidence that the employer deliberately victimized against him/her.From McDonnell Douglas, it remained unclear the exact extent by whichthe plaintiff could meet the definitive burden of persuasion [CITATION Deb94 l 1033 ].

UnderMcDonnell Douglas, as soon as Hicks provided substantial evidence onthe matter, a prima facie discrimination case, Texas Department ofCommunity Affairs Vs. Burdine, an assumption came about that thepetitioners illegally discriminated against him. In that regard,judgment was given in his favor unless or until the petitionersprovided explanations. The assumption mandated the petitioners theload of providing proof that the hostile action taken was legitimateand nondiscriminatory. At this point, the employer must provideenough evidence to legitimize the action. Nevertheless, allassumptions as demonstrated in the case, Hicks had the ultimateburden of persuasion [ CITATION Nor94 l 1033 ].


Althoughthe ‘Supreme Court’ tried in ‘Aikens and Burdine’ toelucidate and perfect the ‘McDonnell Douglas structure,’ thecentralized circuits were still undecided on the exact way that a‘Title VII’ petitioner releases his or her eventual duty ofpersuading. Before the St. Mary’s ruling, most of the circuits hadthe opinion that on proving the respondent’s submitted explanationsas the pretext, the complainant was guaranteed judgment by law. Thecrucial facet, in this case, was the actual “pretext” strategy.It does not necessitate the respondent to provide evidence whetherthe perpetrator deliberately discriminated against him/her. TheEleventh, Eighth, Fifth, Third, and Second Circuits adopted thispretext strategy [ CITATION Nor94 l 1033 ].

Asearlier mentioned, ‘Rule 301 of the Federal Rules of Evidence’controls the utilization of assumptions. A respondent’s realizationof an apparent case under the ‘McDonnell Douglas’ structuredevelops a rebuttable assumption that Title VII prohibits thediscriminatory employment activity. Consequently, ‘Rule 301 is keyto the Title VII’ deliberate occupation discernment events. The lawdecrees that the person against whom the assumption is raised oughtto take over the burden of providing proof to refute thepresupposition [ CITATION Nor94 l 1033 ].


Eventhough the majority openly vetoed the pretext only situation, thestandard of evidence implemented is still questionable. In additionto that, the majority provided conflicting findings. In one part itallows for the evidence of pretext and prima facie case to inferdiscriminations. Whereas on the other part, it requires for the twofacets to be backed up with sufficient proof to sustain theplaintiff’s claims. Evidently, the respondent had providedappropriate information to suggest the employer’s actions wereunfair. At first, Hicks was regarded as one the best performers underthe previous supervisor. It is, therefore, poses a query how hisperformance deteriorated at a considerable rate when the bosses werechanged [CITATION Deb94 l 1033 ].

However,the employer could also argue that Hicks’ performance was becomingpoorer. According to the employer, the basis for discharging theplaintiff was not based on race. The district court concurs with theperpetrator with a view that if the firing was based on race, thenthe panel could have constituted only whites. In other words, thedisciplinary committee had a significant number of African Americans.Additionally, the African American numbers in the facility did notchange over the period Hicks was facing demoting and discharge.Arguing from this perspective, one would think the entire reasonHicks was demoted and discharged was based on personal circumstancesthat were not founded on race [ CITATION Nor94 l 1033 ].

Fromthe above rulings, it is evident that the contentious issue emanatedfrom the extent of proof the respondent had to provide to build acase against the facility. According to the majority ruling, theprima facie case and pretext evidence are not of much value but workas a means of determining the ultimate discrimination problem.Therefore, after the initial offering of the proof, the remainingpart required the respondent to prove discrimination by a majority ofthe proof [ CITATION Nor94 l 1033 ].

However,throughout the verdicts, the majority’s view on St. Mary’s tendsto be consistent with McDonnell Douglas that allows the fact finderto assume deliberate discrimination on the rejection of theplaintiff’s proffered explanations. According to McDonnell, afterthe perpetrator replied to the complainant’s apparent case, ‘TitleVII’ does not provide relief to the petitioner unless the evidenceprovided are a pretext to discrimination forbidden by the Title VII[CITATION Deb94 l 1033 ].

Theassertions provided by McDonnell Douglas Court are quite appropriate.The court provided two mechanisms of proving discrimination, that is,either circumstantial or direct evidence. The entire case is quitecontradicting with insufficient grounds to make judgments. Therefore,the available laws are open for debate. Judgments can vary with bothplaintiff and defendant having insufficient grounds to make theircase. The Court could have clarified the appropriate evidence neededto meet the ultimate burden of proof.


Calloway, D. (1994). St. Mary`s Honor Center v. Hicks: Questioning the Basic Assumption. 997-1038.

Odell, J. H. (2014). Between Pretext Only and Pretext Plus: Understanding St. Mary`s Honor Center v. Hicks and its Application to Judgment. 1250-1283.

St. Mary’s Honor Center v. Hicks,, 509 U.S. 502 (1993) (The Supreme Court 1993).

Whitis, N. (1994). St. Mary`s Honor Center v. Hicks: The Title VII Shifting Burden Stays Put. Loyal University Chicago Law Journal, 269-302.