Second Circuit Revives Race Discrimination Case, Citing SCOTUS “Reeves” Decision

In Sands v. New Paltz Central School District, a race discrimination case, the Second Circuit vacated the district court’s order granting defendants’ motion for summary judgment. Citing the Supreme Court’s decision in Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (2000), the court explained:

[A] plaintiff’s prima facie case … when combined with sufficient evidence to find that the employer’s asserted justification is false, may permit the trier of fact to conclude that the employer unlawfully discriminated. Of course, [t]his is not to say that such a showing by the plaintiff will always be adequate to sustain a jury’s finding of liability. Indeed, there will be instances where, although the plaintiff has established a prima facie case and set forth sufficient evidence to reject the defendant’s explanation, no rational factfinder could conclude that the action was discriminatory. But it is err[or] [to] proceed[ ] from the premise that a plaintiff must always introduce additional, independent evidence of discrimination. (Emphasis added.)

The court cited Cross v. N.Y. City Transit Auth., 417 F.3d 241 (2d Cir. 2005) for the proposition that the Reeves decision “prevents courts from imposing a per se rule requiring in all instances that a[ ] … claimant offer more than a prima facie case and evidence of pretext.”

Applying the law, it held that the district court erred “in holding that plaintiff’s proof that defendants’ explanation was false was ‘immaterial’ because she had not introduced additional, independent evidence of discrimination” and “in failing to consider ‘the probative value of [that] proof’ as well as ‘the strength of … plaintiff’s prima facie case.’”

Based on its own analysis, the Second Circuit concluded that the evidence (if credited) “could support a jury’s finding that [defendants’] rationale for [plaintiff’s denial of tenure] and eventual termination was a pretext for illegal race discrimination.”

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