burden-shifting framework (Maryland) · Go Syfert
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burden-shifting framework in Maryland

14 Maryland opinions name it 2 courts 1976–2026 6 in the last five years

The cases below were cited by Maryland courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (10)

CaseFollowedCited
McDonnell Douglas Corp. v. Greengreen
scotus · 1973 · cited in 6 Maryland opinions naming this issue, 2007–2025
2 sentences

2025This burden-shifting framework was originally announced by the Supreme Court of the United States in McDonnell Douglas. - 11 - In McDonnell Douglass, 411 U.S. at 800, 802 , the Supreme Court held, in a private, non-class action complaint under Title VII alleging racial employment discrimination, that the complainant has the burden of establishing a prima facie case, which can be satisfied by showing that (i) the complainant belongs to a racial minority; (ii) the complainant applied and was qualified for a job the employer was trying to fill; (iii) though qualified, the complainant was rejected

2025Recently, in Ames v. Ohio Dep’t of Youth Servs., 605 U.S. ___ , ___, 145 S. Ct. 1540 , 1545 (2025), the Supreme Court explained: In McDonnell Douglas, this Court laid out a three-step burden-shifting framework for evaluating claims arising under that provision. 411 U. S. at 802-804 , 93 S. Ct. 1817 .

16
Dobkin v. University of Baltimore School of Lawgreen
mdctspecapp · 2013 · cited in 2 Maryland opinions naming this issue, 2018–2024
2 sentences

2024App. 32, 45 (2018) (referencing Dobkin, 210 Md.

2018See Dobkin , 210 Md.

12
Upman v. Clarkegreen
md · 2000 · cited in 1 Maryland opinions naming this issue, 2026–2026
1 sentence

2026See Upman v. Clarke, 359 Md. 32 , 41–43 (2000).

11
Lockheed Martin Corp. v. Balderramagreen
mdctspecapp · 2016 · cited in 1 Maryland opinions naming this issue, 2025–2025
1 sentence

2025See Lockheed Martin Corp. v. Balderrama, 227 Md.

11
Belfiore v. Merch. Link, LLCgreen
mdctspecapp · 2018 · cited in 1 Maryland opinions naming this issue, 2024–2024
1 sentence

2024Best provided legally sufficient evidence, such that a reasonable juror could conclude that MDH’s reasons for transferring Best were mere pretext for discrimination, satisfying the McDonnell Douglas burden- shifting framework. “[I]n cases where the evidence of discrimination is circumstantial rather than direct, Maryland courts apply the three-step burden-shifting analysis first articulated 38 in McDonnell Douglas . . . .” Belfiore v. Merchant Link, LLC, 236 Md.

11
Jimmy Haynes v. Waste Connections, Inc.green
ca4 · 2019 · cited in 1 Maryland opinions naming this issue, 2024–2024
1 sentence

2024Rather, a plaintiff must only show that he was qualified for the job and that he was meeting his employer’s legitimate expectations.” Haynes v. Waste Connections, Inc., 922 F.3d 219, 225 (4th Cir. 2019).

11
Lockshin v. Semskergreen
md · 2010 · cited in 1 Maryland opinions naming this issue, 2023–2023
1 sentence

2023A Our “primary goal in interpreting statutory language is to discern the legislative purpose, the ends to be accomplished, or the evils to be remedied by the statutory provision under scrutiny.” Lockshin v. Semsker, 412 Md. 257, 274 (2010).

11
William Price v. Tommy G. Thompson, Secretary, United States Department of Health and Human Servicesgreen
ca4 · 2004 · cited in 1 Maryland opinions naming this issue, 2023–2023
1 sentence

2023To establish a prima facie claim of unlawful retaliation under McDonnell Douglas, the plaintiff must present evidence showing: (1) “she engaged in protected activity,” (2) the “employer took adverse action against her,” and (3) “a causal relationship existed between the protected activity and the adverse employment activity.” Foster, 787 F.3d at 250 (quoting Price v. Thompson, 380 F.3d 209, 212 (4th Cir. 2004) (cleaned up)).

11
Molina v. Stategreen
mdctspecapp · 2019 · cited in 1 Maryland opinions naming this issue, 2020–2020
1 sentence

2020Molina v. State, 244 Md.

11
John D. Starceski, at No. 94-3208 v. Westinghouse Electric Corporation, at No. 94-3182green
ca3 · 1995 · cited in 1 Maryland opinions naming this issue, 1998–1998
1 sentence

1998Corp., 54 F.3d 1089, 1095-96, n. 4 (3d Cir.1995) (describing difference between the burden shifting framework of pretext cases and mixed-motives cases).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Maryland. Read the followed side critically anyway.

Also cited on this issue (8)

CaseCitedYears
Texas Department of Community Affairs v. Burdine green
scotus · 1981
2 sentences

2025The McDonnell Douglas framework aims to “bring the litigants and the court expeditiously and fairly to th[e] ultimate question” in a disparate-treatment case— namely, whether “the defendant intentionally discriminated against the plaintiff.” Burdine, 450 U. S. at 253 , 101 S. Ct. 1089 .

2025The McDonnell Douglas framework aims to “bring the litigants and the court expeditiously and fairly to th[e] ultimate question” in a disparate-treatment case— namely, whether “the defendant intentionally discriminated against the plaintiff.” Burdine, 450 U. S. at 253 , 101 S. Ct. 1089 .

12025–2025
Foster v. University of Maryland-Eastern Shore green
ca4 · 2015
1 sentence

2023To establish a prima facie claim of unlawful retaliation under McDonnell Douglas, the plaintiff must present evidence showing: (1) “she engaged in protected activity,” (2) the “employer took adverse action against her,” and (3) “a causal relationship existed between the protected activity and the adverse employment activity.” Foster, 787 F.3d at 250 (quoting Price v. Thompson, 380 F.3d 209, 212 (4th Cir. 2004) (cleaned up)).

12023–2023
Molesworth v. Brandon green
md · 1996
2 sentences

2021Molesworth, 341 Md. at 638 , 672 A.2d at 616 . “[T]he employee must first make out a [prima facie] case of discrimination.” Id., 672 A.2d at 617 .

2021Molesworth, 341 Md. at 638 , 672 A.2d at 616 . “[T]he employee must first make out a [prima facie] case of discrimination.” Id., 672 A.2d at 617 .

12021–2021
Haas v. Lockheed Martin Corp. green
md · 2007
2 sentences

2021Haas, 396 Md. at 481 n.8, 914 A.2d at 743 n.8.

2021Haas, 396 Md. at 481 n.8, 914 A.2d at 743 n.8.

12021–2021
Edgewood Management Corp. v. Jackson green
mdctspecapp · 2013
2 sentences

2016Edgewood, 212 Md.App. at 199-200 , 66 A.3d 1152 .

2016Edgewood, 212 Md.App. at 199-200 , 66 A.3d 1152 .

12016–2016
Sandstrom v. Montana green
scotus · 1979
2 sentences

2005Holding that the instruction violated the defendant’s due process rights, the Court declared that the “jury may have interpreted the judge’s instruction as constituting either a burden-shifting presumption ... or a conclusive presumption_” Id. at 524 , 99 S.Ct. 2450 .

2005Holding that the instruction violated the defendant’s due process rights, the Court declared that the “jury may have interpreted the judge’s instruction as constituting either a burden-shifting presumption ... or a conclusive presumption_” Id. at 524 , 99 S.Ct. 2450 .

12005–2005
Western Correctional Institution v. Geiger green
mdctspecapp · 2000
2 sentences

2002If the employee does succeed in showing, prima facie, that the appointing authority was on notice of the purported misconduct on a day more than 30 days before the employee was ultimately disciplined, the disciplinary action shall be rescinded unless the appointing authority proves by a preponderance of the evidence that (1) the investigation required by § 11-106(a)(1) was conducted with reasonable diligence, and (2) the disciplinary action at issue was imposed no later than 30 days after the required investigation had been completed." Id. at 569-70, 747 A.2d at 701 .

2002If the employee does succeed in showing, prima facie, that the appointing authority was on notice of the purported misconduct on a day more than 30 days before the employee was ultimately disciplined, the disciplinary action shall be rescinded unless the appointing authority proves by a preponderance of the evidence that (1) the investigation required by § 11-106(a)(1) was conducted with reasonable diligence, and (2) the disciplinary action at issue was imposed no later than 30 days after the required investigation had been completed.” Id. at 569-70, 747 A.2d at 701 .

12002–2002
Evans v. State green
mdctspecapp · 1975
1 sentence

1976Now, if you were to find from the facts in this case that no robbery was going on, then that rule does not apply and the elements of Murder would be left.” In Evans, supra, (HE 1) at 686, Judge Moylan concluded, after extensive reasoning, that the felony-murder statutes “are, therefore, not remotely affected by anything in Mullaney v. Wilbur. ” He reasoned that it is the mens rea, the malicious intent, which Mullaney forbids to be supplied by a burden-shifting presumption, rather than the actus reus, “the dreaded modality or means of the murder, which we have singled out for our gravest crimin

11976–1976

Where else courts name it

TX 256 (1985–2026) OH 203 (1990–2026) CA 190 (1985–2026) MI 113 (1980–2026) NJ 79 (1991–2026) CT 65 (1988–2026) TN 52 (1999–2026) NY 48 (1980–2026) WA 41 (1981–2025) MA 38 (1980–2026) PA 35 (1976–2026) KY 32 (2005–2026) FL 32 (1988–2026) GA 30 (1981–2025) ME 29 (2003–2025) LA 28 (1992–2023) IN 27 (1991–2026) MN 26 (1997–2025) MO 25 (1998–2025) NC 24 (2005–2025) IL 24 (1998–2026) OR 23 (1994–2026) IA 23 (1985–2026) KS 22 (1979–2024) VT 21 (1982–2025) RI 20 (2001–2019) HI 18 (1996–2025) DC 17 (1995–2026) WV 14 (1982–2025) MD 14 (1976–2026) UT 12 (1999–2025) ID 11 (1980–2023) VA 11 (1990–2026) AZ 10 (1982–2026) WI 10 (1979–2025) AL 10 (1991–2023) CO 10 (1990–2025) NV 10 (2020–2025) NE 10 (2006–2024) DE 8 (2011–2025) SC 7 (1984–1996) NM 7 (1991–2025) AK 7 (1982–2022) SD 6 (2003–2019) MT 6 (1979–2007) MS 4 (2000–2020) NH 4 (2016–2025) WY 4 (2007–2018) OK 2 (2012–2020) ND 2 (2001–2004) AR 2 (1951–2011) PR 2 (2011–2026)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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