Summary of Price Waterhouse v. Hopkins
Relevant Facts: Hopkins sued Price Waterhouse over sexual discrimination because she was refused partnership in the firm. Hopkins filed the suit in federal district court and alleged that Price Waterhouse’s discrimination against her violated Title VII, which “prohibits discrimination by covered employers on the basis of race, color, religion, sex or national origin." Price Waterhouse affirmed that Hopkins was eligible for partnership, but because of apparent deficiencies in interpersonal relations and her outward appearance, e.g. the way she dressed, she was denied partnership. Hopkins argued that she was being specifically singled out and therefore her discrimination fell under the criteria laid out under disparate treatment provisions. The matter was sent to the district and federal appeals courts on the issue of whether Hopkins had been illegally discriminated against. While both courts agreed that she had been discriminated against, they disagreed as to the level of proof needed to demonstrate that sexual discrimination had taken place. The Supreme Court ruled on the issue the following year.
Issue: The legal question at hand was whether Price Waterhouse’s rationale of denying Ann Hopkins a promotion on the basis of deficient interpersonal skills was in fact a legitimate basis on which to deny her partnership, or just a pretext for sexual discrimination in violation of Title VII.
Holding: The Supreme Court held that Price Waterhouse had illegally discriminated against Hopkins. It should be noted that there was no majority on the matter, but rather a plurality, and the justices held slightly different viewpoints although overall agreed with each other.
Majority Opinion Reasoning: The Court reasoned that the company had to prove by a preponderance of the evidence that their decision to deny Hopkins a promotion would have been the same if she had not been discriminated based on her sex and her lack of femininity. The company could not meet that burden; it was implicit that the same treatment would not have applied to a male counterpart. Therefore, the firm was guilty of committing sex-based discrimination against Hopkins in violation of Title VII of the 1964 Civil Rights Act.
Dissenting Opinion: Associate Justice O’Connor presented a dissenting opinion and argued that in order to reasonably shift the burden of proof to a defendant, the plaintiff must have more convincing probative evidence than in pretext cases in which discrimination has occurred. O’Connor further reasoned that when there is direct evidence that discrimination has been intentional, placing a greater burden on the defendant is prudent.
Conclusion: The case was significant because it established that sexual discrimination on the basis of gender stereotyping is an actionable offense. Sexual discrimination can include an array of offenses which can include stereotyping an individual’s behavior as sufficient or insufficient regarding their gender. Additionally, the ruling established a mixed-motive framework as a means of providing evidence for discrimination claims using disparate treatment theory even in cases where employer actions (denial of a promotion or termination of an employee) exist for other potentially legitimate reasons.