United States Postal Service Board of Governors v. Aikens
Headline: Court vacates and remands a race-discrimination promotion case, sending a retired Black postal worker’s claim back for reconsideration and leaving the proof standard uncertain.
Holding: The Court granted review, vacated the appeals court's judgment, and remanded the retired Black postal worker's discrimination case for reconsideration in light of Texas Dept. of Community Affairs v. Burdine.
- Leaves the standard for promotion discrimination unclear pending reconsideration.
- May make it harder for applicants to survive early dismissal of claims.
- Gives appeals court chance to reconsider application of McDonnell Douglas standard.
Summary
Background
Respondent Louis Aikens is a retired Black employee of the United States Postal Service who sued the Postal Service Board of Governors under Title VII, arguing race discrimination in promotions and work details. The District Court dismissed his suit, saying he failed to show that he was "as qualified or more qualified" than those promoted. The Court of Appeals reversed, finding the District Court misapplied the law and holding that the plaintiff need only show he applied and was qualified for the job, per McDonnell Douglas, and remanded for further proceedings.
Reasoning
The immediate question was whether a job-seeking applicant must prove he was as qualified as the person chosen to make a prima facie discrimination case. The Supreme Court granted review, vacated the Court of Appeals judgment, and remanded the case for reconsideration in light of this Term's decision in Texas Dept. of Community Affairs v. Burdine. The majority provided no opinion explaining the remand. Justice Marshall, joined by Justice Brennan, dissented, arguing Texas Dept. of Community Affairs addressed burdens after a prima facie showing and did not change the McDonnell Douglas requirement that a plaintiff only show he was qualified.
Real world impact
Because the Court vacated and remanded without a written explanation, the legal standard for proving promotion discrimination is left unclear pending the appeals court's reconsideration. The ruling is not a final decision on whether the Postal Service discriminated. The outcome on remand could affect how easily job applicants can survive early dismissal of discrimination claims.
Dissents or concurrances
Justice Marshall's dissent sharply opposes the vacatur and remand, saying the appeals court correctly applied existing precedent and that the Court’s action needlessly obscures the law.
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