explaining that to show pretext, the plaintiff must “demonstrate weaknesses or implausibilities in the proffered legitimate reason so as to permit a rational jury to conclude that the explanation given was not the real reason, or that the reason stated was insufficient to warrant the adverse action”
How later courts described this case
- explaining that to show pretext, the plaintiff must “demonstrate weaknesses or implausibilities in the proffered legitimate reason so as to permit a rational jury to conclude that the explanation given was not the real reason, or that the reason stated was insufficient to warrant the adverse action”
- explaining that if an employer rebuts a prima facie case by producing evidence that it had a legitimate, non-discriminatory reason for the challenged action, the burden shifts back to the plaintiff to “show that the proffered reason really is a pretext for unlawful discrimination”
- holding that while a difference in rank is not dispositive in and of itself, lower-ranked employees may be disciplined differently than higher-ranked employees, “who are held to a higher level of professionalism and who are expected to set the standard of conduct”
- holding that § 1983 provides the exclusive remedy for redressing violations of § 1981 against state actors
Written by the judges who cited it.
Later courts went against this
Overruled in part, on other grounds by Pearson v. Callahan, 555 U.S. 223 (2009)
520 F.3d 1269, 1283 (11th Cir. 2008) (alteration added; citation and quotation marks omitted), abrogated in part on other grounds by Pearson, 555 U.S. 223
The opinion
EDMONDSON, Chief Judge,
concurring in the result:
I would not reach the qualified immunity issue because I think the record established no violation of the Constitution. Plaintiff can point to no comparator. The decisions set out in today’s court opinion to support a prima facie case are not being followed, but are being extended to the disciplinary-demotion situation. I also doubt that Plaintiff has presented suffi *1286 cient evidence of pretext. If I believed this record did establish pretext, I would worry that qualified immunity could not apply: no mixed motive, just an unlawful discriminatory one.