Matter of Pace College v. Commission on Human Rights, 38 N.Y.2d 28 (1975)
In a retaliation claim, once a prima facie showing of discrimination is made, the employer must demonstrate that the termination was for an independent, legitimate reason that was not a pretext for discrimination nor substantially influenced by impermissible discrimination.
Summary
This case addresses the standard for evaluating retaliation claims before the New York City Commission on Human Rights. The complainant was discharged, and one reason given was her prior discrimination complaint (which had been dismissed). The Court of Appeals held that while the Commission correctly found a prima facie case of retaliation, it erred by not considering the legitimacy of the employer’s other reasons for the discharge. The court clarified that a discriminatory reason need not be the sole reason for discharge, but the employer must prove the termination was for legitimate, independent reasons, not a pretext for or substantially influenced by discrimination. The case was remitted for further proceedings consistent with this standard.
Facts
The complainant filed a prior discrimination complaint with the New York City Commission on Human Rights, which was ultimately dismissed.
Subsequently, the complainant was discharged from her employment at Pace College.
One of the reasons Pace College gave for the discharge was the complainant’s prior discrimination complaint.
The Commission on Human Rights found a prima facie case of retaliation.
Procedural History
The New York City Commission on Human Rights ruled in favor of the complainant, finding retaliation.
Pace College appealed the Commission’s decision.
The Appellate Division’s order was reversed by the Court of Appeals.
The case was remitted to the Supreme Court, New York County, with directions to remand to the New York City Commission on Human Rights for further proceedings.
Issue(s)
Whether, in a retaliation case, the employer must prove that the employee’s prior complaint of discrimination was the sole reason for the discharge, or whether the employer must demonstrate that the discharge was for independent, legitimate reasons not influenced by discrimination.
Holding
No, because once a prima facie showing of discrimination is made, the burden shifts to the employer to show that the employee was terminated for some independent legitimate reason which was neither a pretext for discrimination nor was substantially influenced by impermissible discrimination.
Court’s Reasoning
The Court of Appeals determined that the Commission erred in concluding it didn’t need to consider the other reasons stated by Pace College as legitimate, nonretaliatory grounds for the dismissal. The court rejected the Commission’s view that a discriminatory reason