On Tuesday, a New York state appeals court set a high standard for employers charged with discrimination actions under New York City’s human rights law. While the particular case in question was decided in favor of the employers, the court took the opportunity to issue a more general ruling that in such cases, the burden lies on employers to prove their nondiscriminatory motives beyond dispute.
In the case, Kenneth Bennett filed suit against his former employer Health Management Systems Inc., claiming the company fired him for reasons related to his age and race, Thomson Reuters reports. The Manhattan Supreme Court granted summary judgment in favor of Health Management Systems, which said it had received reports of Bennett consuming alcohol on the job, according to court documents.
The appeals court affirmed this ruling, but laid out three guidelines for courts to use when deciding whether to grant summary judgment in cases dealing with the human rights law:
- Courts have to decide whether the facts describe possible discrimination under McDonnell Douglas Corp. v. Green, which requires plaintiffs to make a prima facie case of discrimination based on any protected status such as race, age, sex, etc.
- Then, the court has to determine whether the defendant has shown that a jury could not possibly find it liable for discrimination.
- Lastly, if the plaintiff disputes the defendant’s evidence, the court should allow a jury to decide whether the motives were in fact nondiscriminatory.