Price Waterhouse v. Hopkins
Facts
Ann Hopkins, a senior manager at Price Waterhouse, was proposed for partnership in 1982, but her candidacy was put on hold and later not reproposed. The firm relied heavily on written partner comments in making partnership decisions, and some comments about Hopkins reflected sex stereotyping, including remarks that she was "macho," needed "a course at charm school," and should walk, talk, dress, and appear more femininely. The District Court found that Price Waterhouse legitimately valued interpersonal skills and that criticisms of Hopkins in that area were not fabricated, but also found that sex-stereotyped comments were given credence and effect in the decisionmaking process. The firm did not disclaim reliance on those comments.
Issue
In a Title VII case where an employment decision results from both legitimate and illegitimate motives, what must the plaintiff prove, and what burden does the employer bear to avoid liability? Also, what standard of proof governs the employer's same-decision showing?
Rule
When a Title VII plaintiff proves that her sex played a motivating part in an employment decision, the employer may avoid a finding of liability only by proving by a preponderance of the evidence that it would have made the same decision even if it had not taken sex into account. Sex stereotyping can constitute evidence that gender played a motivating part, but the plaintiff must show the employer actually relied on gender in making the decision.
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If Maya proves the decisionmakers actually relied on both the deadline problems and the sex-based comment in making the promotion decision, what must she show to establish a Title VII mixed-motives case?