McDonnell Douglas Corp. v. Green

Background

A Black mechanic who had worked for the company since 1956 was laid off in a general reduction in 1964. He joined protests against the company's hiring practices, including an illegal "stall-in" that blocked access to the plant and a later "lock-in." After the company advertised for mechanics in 1965 he applied but was not rehired. He filed a complaint with the Equal Employment Opportunity Commission claiming both race-based refusal to hire and retaliation for civil-rights activity. The Commission found reasonable cause for retaliation but not for race, and the company refused to rehire him because of his protest activity.

Reasoning

The Court said the lack of a Commission finding of reasonable cause does not prevent a person from suing in federal court. It described how proof should proceed: the applicant must first show a basic set of facts that suggest discrimination (being a racial minority, applying and being qualified, rejected, and the employer still seeking applicants). If the applicant makes this showing, the employer must give a legitimate, nonracial reason for the rejection. In this case the company cited the applicant’s unlawful demonstrations; that reason meets the employer’s burden, but the applicant may try to prove it was a cover‑up for racial discrimination.

Real world impact

The case sends the dispute back for a new trial so the applicant can try to prove the company’s explanation was pretext — for example by showing that similarly situated white workers were treated differently or by using employment statistics. If the court finds pretext, it must order an appropriate remedy; if not, the refusal to rehire stands. The decision makes clear employers can rely on unlawful acts directed at them as a legitimate reason to refuse hire, unless applied in a discriminatory way.