employer to rebut presumption (New Jersey) · Go Syfert
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employer to rebut presumption in New Jersey

12 New Jersey opinions name it 2 courts 1981–2025 6 in the last five years

The cases below were cited by New Jersey 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 (9)

CaseFollowedCited
Kolb v. Burnsgreen
njsuperctappdiv · 1999 · cited in 5 New Jersey opinions naming this issue, 2021–2025
2 sentences

2025When a plaintiff has sufficiently alleged an employer took an adverse employment action as a pretext for discrimination, "the burden of persuasion is shifted to the employer to rebut the presumption of discrimination by articulating some legitimate nondiscriminatory reason for the adverse employment action." Allen, 246 N.J. at 290-91 (quoting Kolb v. Burns, 320 N.J.

2025To establish a CEPA claim, a plaintiff must demonstrate that: (1) he or she reasonably believed that his or her employer's conduct was violating either a law, rule, or regulation promulgated pursuant to law, or a clear mandate of public policy; (2) he or she performed a "whistle-blowing" activity described in [N.J.S.A. 34:19-3(a)]; A-0838-23 11 (3) an adverse employment action was taken against him or her; and (4) a causal connection exists between the whistle- blowing activity and the adverse employment action. [Lippman v. Ethicon, Inc., 222 N.J. 362, 380 (2015) (quoting Dzwonar, 177 N.J. at

55
Texas Department of Community Affairs v. Burdinegreen
scotus · 1981 · cited in 2 New Jersey opinions naming this issue, 1981–1982
2 sentences

1982See Texas Department of Community Affairs v. Burdine, 450 U.S. 248, 254 , 101 S.Ct. 1089, 1094 , 67 L.Ed. 2d 207, 216 (1981); Board of Trustees v. Sweeney, 439 U.S. 24, 24-26 , 99 S.Ct. 295, 295-96 , 58 L.Ed. 2d 216, 218-19 (1978).

1982See Texas Department of Community Affairs v. Burdine, 450 U.S. 248, 254 , 101 S.Ct. 1089, 1094 , 67 L.Ed. 2d 207, 216 (1981); Board of Trustees v. Sweeney, 439 U.S. 24, 24-26 , 99 S.Ct. 295, 295-96 , 58 L.Ed. 2d 216, 218-19 (1978).

22
Board of Trustees of Keene State College v. Sweeneygreen
scotus · 1978 · cited in 2 New Jersey opinions naming this issue, 1981–1982
2 sentences

1982See Texas Department of Community Affairs v. Burdine, 450 U.S. 248, 254 , 101 S.Ct. 1089, 1094 , 67 L.Ed. 2d 207, 216 (1981); Board of Trustees v. Sweeney, 439 U.S. 24, 24-26 , 99 S.Ct. 295, 295-96 , 58 L.Ed. 2d 216, 218-19 (1978).

1982See Texas Department of Community Affairs v. Burdine, 450 U.S. 248, 254 , 101 S.Ct. 1089, 1094 , 67 L.Ed. 2d 207, 216 (1981); Board of Trustees v. Sweeney, 439 U.S. 24, 24-26 , 99 S.Ct. 295, 295-96 , 58 L.Ed. 2d 216, 218-19 (1978).

22
Peper v. Princeton University Board of Trusteesgreen
nj · 1978 · cited in 2 New Jersey opinions naming this issue, 1982–1988
2 sentences

1982Relying on McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802 , 93 S.Ct. 1817, 1824 , 36 L.Ed. 2d 668, 678 (1973), this Court has previously adhered to the concept that once plaintiff's prima facie showing is made, thereby giving rise to a presumption of unlawful discrimination, the burden of going forward shifts to the employer to rebut the presumption by "articulat[ing] some legitimate, nondiscriminatory reason for the employee's rejection." Goodman v. London Metals Exchange, Inc., 86 N.J. at 31 ; Peper v. Princeton University Board of Trustees , 77 N.J. at 83.

1982Relying on McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802 , 93 S.Ct. 1817, 1824 , 36 L.Ed.2d 668, 678 (1973), this Court has previously adhered to the concept that once plaintiff’s prima facie showing is made, thereby giving rise to a presumption of unlawful discrimination, the burden of going forward shifts to the employer to rebut the presumption by “articulatpng] some legitimate, nondiscriminatory reason for the employee’s rejection.” Goodman v. London Metals Exchange, Inc., 86 N.J. at 31 ; Peper v. Princeton University Board of Trustees, 77 N.J. at 83.

12
McDonnell Douglas Corp. v. Greengreen
scotus · 1973 · cited in 2 New Jersey opinions naming this issue, 1981–1982
2 sentences

1982Relying on McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802 , 93 S.Ct. 1817, 1824 , 36 L.Ed. 2d 668, 678 (1973), this Court has previously adhered to the concept that once plaintiff's prima facie showing is made, thereby giving rise to a presumption of unlawful discrimination, the burden of going forward shifts to the employer to rebut the presumption by "articulat[ing] some legitimate, nondiscriminatory reason for the employee's rejection." Goodman v. London Metals Exchange, Inc., 86 N.J. at 31 ; Peper v. Princeton University Board of Trustees , 77 N.J. at 83.

1982Relying on McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802 , 93 S.Ct. 1817, 1824 , 36 L.Ed. 2d 668, 678 (1973), this Court has previously adhered to the concept that once plaintiff's prima facie showing is made, thereby giving rise to a presumption of unlawful discrimination, the burden of going forward shifts to the employer to rebut the presumption by "articulat[ing] some legitimate, nondiscriminatory reason for the employee's rejection." Goodman v. London Metals Exchange, Inc., 86 N.J. at 31 ; Peper v. Princeton University Board of Trustees , 77 N.J. at 83.

12
Joel S. Lippman, M.D. v. Ethicon, Inc. (073324)green
nj · 2015 · cited in 1 New Jersey opinions naming this issue, 2025–2025
1 sentence

2025To establish a CEPA claim, a plaintiff must demonstrate that: (1) he or she reasonably believed that his or her employer's conduct was violating either a law, rule, or regulation promulgated pursuant to law, or a clear mandate of public policy; (2) he or she performed a "whistle-blowing" activity described in [N.J.S.A. 34:19-3(a)]; A-0838-23 11 (3) an adverse employment action was taken against him or her; and (4) a causal connection exists between the whistle- blowing activity and the adverse employment action. [Lippman v. Ethicon, Inc., 222 N.J. 362, 380 (2015) (quoting Dzwonar, 177 N.J. at

11
Zive v. Stanley Roberts, Inc.green
nj · 2005 · cited in 1 New Jersey opinions naming this issue, 2021–2021
1 sentence

2021If the plaintiff establishes a prima facie case, the burden of production shifts to the employer to rebut the presumption of discrimination by articulating "a legitimate, nondiscriminatory reason for the employer's action." Zive v. Stanley Roberts, Inc., 182 N.J. 436, 449 (2005) (citing Clowes v. Terminix Int'l, Inc., 109 N.J. 575, 596 (1988)).

11
Clowes v. Terminix International, Inc.green
nj · 1988 · cited in 1 New Jersey opinions naming this issue, 2021–2021
2 sentences

2021If the plaintiff establishes a prima facie case, the burden of production shifts to the employer to rebut the presumption of discrimination by articulating "a legitimate, nondiscriminatory reason for the employer's action." Zive v. Stanley Roberts, Inc., 182 N.J. 436, 449 (2005) (citing Clowes v. Terminix Int'l, Inc., 109 N.J. 575, 596 (1988)).

2021If the employer satisfies its burden, "the burden of production shifts back to the employee to prove by a preponderance of the evidence that the reason articulated by the employer was merely a pretext for discrimination and not the true reason for the employment decision." Ibid.

11
Furnco Construction Corp. v. Watersgreen
scotus · 1978 · cited in 1 New Jersey opinions naming this issue, 1981–1981
2 sentences

1981See Texas Department of Community Affairs v. Burdine, - U.S. at -, 101 S.Ct. at 1094 , 67 L.Ed.2d at *32 215; Board of Trustees v. Sweeney, 439 U.S. 24, 24-26 , 99 S.Ct. 295, 295-296 , 58 L.Ed.2d 216, 218-219 (1978); Furnco Construction Co. v. Waters, 438 U.S. 567, 576-578 , 98 S.Ct. 2943, 2949-2950 , 57 L.Ed.2d 957, 967-968 (1978).

1981See Texas Department of Community Affairs v. Burdine, - U.S. at -, 101 S.Ct. at 1094 , 67 L.Ed.2d at *32 215; Board of Trustees v. Sweeney, 439 U.S. 24, 24-26 , 99 S.Ct. 295, 295-296 , 58 L.Ed.2d 216, 218-219 (1978); Furnco Construction Co. v. Waters, 438 U.S. 567, 576-578 , 98 S.Ct. 2943, 2949-2950 , 57 L.Ed.2d 957, 967-968 (1978).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (7)

CaseCitedYears
Dzwonar v. McDevitt green
nj · 2003
2 sentences

2025To establish a CEPA claim, a plaintiff must demonstrate that: (1) he or she reasonably believed that his or her employer's conduct was violating either a law, rule, or regulation promulgated pursuant to law, or a clear mandate of public policy; (2) he or she performed a "whistle-blowing" activity described in [N.J.S.A. 34:19-3(a)]; A-0838-23 11 (3) an adverse employment action was taken against him or her; and (4) a causal connection exists between the whistle- blowing activity and the adverse employment action. [Lippman v. Ethicon, Inc., 222 N.J. 362, 380 (2015) (quoting Dzwonar, 177 N.J. at

2024Where a plaintiff presents sufficient evidence establishing a prima facie CEPA claim under N.J.S.A. 34:19-3(c), "the burden of persuasion is shifted to the employer to rebut the presumption of [unlawful retaliation] by articulating some legitimate non[-retaliatory] reason for the adverse employment action." Id. at 290-91 (quoting Kolb v. Burns, 320 N.J.

22024–2025
Andersen v. Exxon Co. green
nj · 1982
2 sentences

2000The plaintiff then has the opportunity to prove by a preponderance of the evidence that the legitimate nondiscriminatory reason articulated by the defendant was not the true reason for the employment decision but was merely a pretext for discrimination. [Andersen v. Exxon, 89 N.J. 483, 492-93 , 446 A2.d 486 (1982).] The controversy in this case turns on the second stage, in which the defendant has the burden of going forward to advance or articulate one or more legitimate nondiseriminating reasons for its actions.

1999Andersen, supra, 89 N.J. at 493 , 446 A. 2d 486 ; Mogull v. CB Commercial Real Estate Group, Inc., 319 N.J.Super. 53, 65 , 724 A. 2d 863 (App.Div.1999); Maiorino v. Schering-Plough Corp., 302 N.J.Super. 323, 346 , 695 A. 2d 353 (App. Div.), certif. denied, 152 N.J. 189 , 704 A. 2d 19 (1997).

21999–2000
Maiorino v. Schering-Plough Corp. green
njsuperctappdiv · 1997
2 sentences

1999Andersen, supra, 89 N.J. at 493 , 446 A. 2d 486 ; Mogull v. CB Commercial Real Estate Group, Inc., 319 N.J.Super. 53, 65 , 724 A. 2d 863 (App.Div.1999); Maiorino v. Schering-Plough Corp., 302 N.J.Super. 323, 346 , 695 A. 2d 353 (App. Div.), certif. denied, 152 N.J. 189 , 704 A. 2d 19 (1997).

1999Andersen, supra, 89 N.J. at 493 , 446 A. 2d 486 ; Mogull v. CB Commercial Real Estate Group, Inc., 319 N.J.Super. 53, 65 , 724 A. 2d 863 (App.Div.1999); Maiorino v. Schering-Plough Corp., 302 N.J.Super. 323, 346 , 695 A. 2d 353 (App. Div.), certif. denied, 152 N.J. 189 , 704 A. 2d 19 (1997).

21998–1999
Goodman v. London Metals Exchange, Inc. green
nj · 1981
2 sentences

1982Relying on McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802 , 93 S.Ct. 1817, 1824 , 36 L.Ed. 2d 668, 678 (1973), this Court has previously adhered to the concept that once plaintiff's prima facie showing is made, thereby giving rise to a presumption of unlawful discrimination, the burden of going forward shifts to the employer to rebut the presumption by "articulat[ing] some legitimate, nondiscriminatory reason for the employee's rejection." Goodman v. London Metals Exchange, Inc., 86 N.J. at 31 ; Peper v. Princeton University Board of Trustees , 77 N.J. at 83.

1982Relying on McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802 , 93 S.Ct. 1817, 1824 , 36 L.Ed.2d 668, 678 (1973), this Court has previously adhered to the concept that once plaintiff’s prima facie showing is made, thereby giving rise to a presumption of unlawful discrimination, the burden of going forward shifts to the employer to rebut the presumption by “articulatpng] some legitimate, nondiscriminatory reason for the employee’s rejection.” Goodman v. London Metals Exchange, Inc., 86 N.J. at 31 ; Peper v. Princeton University Board of Trustees, 77 N.J. at 83.

21982–1988
Mogull v. CB Commercial Real Estate Group, Inc. green
njsuperctappdiv · 1999
2 sentences

1999Andersen, supra, 89 N.J. at 493 , 446 A. 2d 486 ; Mogull v. CB Commercial Real Estate Group, Inc., 319 N.J.Super. 53, 65 , 724 A. 2d 863 (App.Div.1999); Maiorino v. Schering-Plough Corp., 302 N.J.Super. 323, 346 , 695 A. 2d 353 (App. Div.), certif. denied, 152 N.J. 189 , 704 A. 2d 19 (1997).

1999Andersen, supra, 89 N.J. at 493 , 446 A. 2d 486 ; Mogull v. CB Commercial Real Estate Group, Inc., 319 N.J.Super. 53, 65 , 724 A. 2d 863 (App.Div.1999); Maiorino v. Schering-Plough Corp., 302 N.J.Super. 323, 346 , 695 A. 2d 353 (App. Div.), certif. denied, 152 N.J. 189 , 704 A. 2d 19 (1997).

11999–1999
Maiorino v. Schering-Plough Corporation green
nj · 1997
1 sentence

1999Andersen, supra, 89 N.J. at 493 , 446 A. 2d 486 ; Mogull v. CB Commercial Real Estate Group, Inc., 319 N.J.Super. 53, 65 , 724 A. 2d 863 (App.Div.1999); Maiorino v. Schering-Plough Corp., 302 N.J.Super. 323, 346 , 695 A. 2d 353 (App. Div.), certif. denied, 152 N.J. 189 , 704 A. 2d 19 (1997).

11999–1999
cluster 744491 green
ca3 · 1997
1 sentence

1998Maiorino v. Schering-Plough Corp., supra, 302 N.J.Super. at 345-47 , 695 A.2d 353 . “ ‘To accomplish this, the defendant must clearly set forth, through the introduction of admissible evidence, the reasons for the plaintiffs rejection’ which would support a jury finding that unlawful discrimination was not the cause of the adverse employment action.” Stewart v. Rutgers, supra, 120 F.3d at 432 (quoting St.

11998–1998

Statutes the citing opinions construe

NJ § N.J. Stat. § 34:19-1 (5) NJ § N.J. Stat. § 34:19-3 (5)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 48 (1931–2025) NY 13 (1985–2026) NJ 12 (1981–2025) DC 8 (1985–2017) TX 8 (1999–2024) PA 7 (2001–2022) TN 5 (1993–1999) MT 4 (1994–2001) LA 4 (1937–2003) MA 3 (2021–2024) NC 3 (1998–2017) WA 3 (2014–2022) HI 2 (2002–2008) VT 2 (2015–2015) MI 2 (2023–2025) GA 2 (1995–1997) IA 2 (2004–2014)

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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