Douglas M. Mills v. Health Care Service Corporation
171 F.3d 450 (1999)
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Rule of Law:
In a Title VII reverse discrimination claim, a plaintiff who is a member of a majority group must establish a prima facie case by showing 'background circumstances' which support an inference that the defendant is one of those unusual employers who discriminates against the majority.
Facts:
- Douglas M. Mills began working at Health Care Service Corporation's (HCSC) Quincy office in 1988 and generally received favorable work reviews.
- In 1995, after a co-manager resigned, HCSC created a new assistant manager position to be filled by the remaining manager, Linda Amburn.
- Mills and three women, including Darlene Butler, applied for the assistant manager position.
- After interviewing both Mills and Butler, Amburn offered the position to Butler.
- Mills believed his qualifications were superior to Butler's and that he was denied the promotion based on his gender.
Procedural Posture:
- Douglas M. Mills filed a gender discrimination lawsuit against Health Care Service Corporation (HCSC) under Title VII in federal district court.
- HCSC filed a motion for summary judgment.
- The district court granted summary judgment in favor of HCSC, finding that Mills failed to prove that the company's reasons for its hiring decision were pretextual.
- Mills, as the appellant, appealed the grant of summary judgment to the U.S. Court of Appeals for the Seventh Circuit.
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Issue:
Does a male plaintiff in a reverse gender discrimination suit under Title VII need to show 'background circumstances' suggesting the employer has a reason or inclination to discriminate against the majority in order to establish a prima facie case of discrimination?
Opinions:
Majority - Flaum, Circuit Judge.
Yes. A male plaintiff in a reverse discrimination suit must show background circumstances that suggest the employer is the unusual employer who discriminates against the majority. The standard McDonnell Douglas prima facie test is modified because its first prong—membership in a protected class—is not met by a majority plaintiff, and discrimination against the majority is presumed to be uncommon. To establish a prima facie case, such a plaintiff must show background circumstances, such as evidence that the employer has an inclination to discriminate against the majority or that there is something 'fishy' about the facts. Here, Mills satisfied this modified test by showing that females dominated supervisory positions and that nearly all promotions at the office went to women. However, his claim ultimately fails because HCSC articulated legitimate, non-discriminatory reasons for hiring Butler—namely her superior qualifications, interview performance, and broader experience. Mills failed to demonstrate that all of these proffered reasons were a pretext for discrimination, as he is required to do to survive summary judgment.
Analysis:
This decision formally adopts the 'background circumstances' requirement for prima facie reverse discrimination cases in the Seventh Circuit, aligning it with other circuits like the D.C. and Tenth. It clarifies the initial burden on plaintiffs from majority groups, making it more difficult for them to proceed with a discrimination claim without evidence suggesting the employer has a pattern or reason to discriminate against the majority. This standard serves as a screening mechanism to filter out ordinary personnel decisions from potentially meritorious reverse discrimination claims, reinforcing the idea that Title VII's core purpose was to protect historically disadvantaged groups.
