Facts of the Case
The plaintiffs in this case were two black employees (Anthony Ash and John Hithon) who filed against racial discrimination by their employer (Tyson Foods Inc.) which was the defendant in the case. Ash and Hithon claimed that they had been discriminated against by the defendant when he promoted white employees who were clearly less qualified than them. The two employees had applied for promotions in the position of open shift manager but subsequently the two white colleagues were promoted, prompting them to file a case of racial discrimination at the US district court for Northern District of Alabama.
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"Ash vs. Tyson Foods, Inc.".
The two plaintiffs provided evidence to support claims. The evidences were accessed by the district court which ordered a new trial after granting judgement as a matter of law. The court of appeals ruled that the evidence provided was insufficient to prove that there was stack difference between the two sets of employees (the plaintiffs and the two promoted whites) to implicate the defendant as having violated the rights of the plaintiffs by discriminating against them. The plaintiffs appealed in the US Supreme Court.
Issues
Whether the District Circuit Court used the right procedure and evidence to establish if the employer’s claimed nondiscriminatory reason for promotion decision is pre-textual.
Whether the use of the word ‘boy’ in reference to an employee can be used as evidence of racial discrimination.
Decisions (Holdings)
The court delivered a per curiam opinion in which it gave a Yes and NO ruling to the two issues listed above.
Reasoning (Rationale)
The court’s ruling was an anonymous and unanimous per curiam opinion in which it observed that two main errors had been made by the Circuit court in its initial ruling of the case. Regarding the first issue, the Supreme Court observed that the circuit court had failed to develop a precise standard which could have been used to determine whether the hiring practices had amounted in discrimination of the plaintiffs. The Supreme Court argued that the circuit court had failed to establish a standard for pretext claims with respect to the superiority of the qualifications of the plaintiffs as compared to that of the two white men who had been promoted in their stead.
Regarding the second issue of the plaintiffs being referred to as ‘boys’, the supreme court argued that the word ‘boy’ cannot be always regarded as alluding racists sentiments. The court observed that for the term to be considered racists, a number of factors would have to be analyzed. Such factors that influence the meaning of the term ‘boy’ include the context in which it used, the tone of the voice used by the employer when uttering the term, the historical context of the use of the term, and inflection among other factors. Based on this argument, the Supreme Court judged that the circuit court had failed to establish the correct context in which the word ‘boy’ was used and whether such context amounted to racial behavior.
The Supreme Court concluded that the circuit court had made the two errors analyzed above and hence it was not possible to determine if the circuit court’s ruling was fair. The Supreme Court subsequently reversed the Circuit Court ruling and ordered that the lower court determines if the errors identified had affected the outcome of its ruling.
Separate Opinions
Not applicable. The case did not have dissenting opinions since the rulings were anonymous and unanimous.
Analysis
This case is very significant due to the sensitivity of the issue in the society. Workplace discrimination is an issue of concern that should be discouraged through the justice department. The decision of the Supreme Court to overrule the Circuit Court’s ruling is very prudent since the Circuit Court did not take the case seriously hence the many errors in the case.
