10 Maryland opinions name it 2 courts 2000–2025 5 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.
| Case | Followed | Cited |
|---|---|---|
Belfiore v. Merch. Link, LLCgreen2 sentences2025Accord Belfiore, 236 Md. 2025Accord Belfiore, 236 Md. | 1 | 1 |
Dobkin v. University of Baltimore School of Lawgreen2 sentences2024Under the McDonnell Douglas framework, once a plaintiff meets the initial burden of proving a prima facie case by a preponderance of the evidence, “[t]he burden of production then shifts to the employer to . . . provide ‘some legitimate, nondiscriminatory reason’ for the adverse employment action.” Sharif v. United Airlines, Inc., 841 F.3d 199, 203 (4th Cir. 2016) (quoting McDonnell Douglas, 410 U.S. at 802); see also Dobkin, 210 Md. 2024Under the McDonnell Douglas framework, once a plaintiff meets the initial burden of proving a prima facie case by a preponderance of the evidence, “[t]he burden of production then shifts to the employer to . . . provide ‘some legitimate, nondiscriminatory reason’ for the adverse employment action.” Sharif v. United Airlines, Inc., 841 F.3d 199, 203 (4th Cir. 2016) (quoting McDonnell Douglas, 410 U.S. at 802); see also Dobkin, 210 Md. | 1 | 1 |
Masoud Sharif v. United Airlines, Inc.green2 sentences2024Under the McDonnell Douglas framework, once a plaintiff meets the initial burden of proving a prima facie case by a preponderance of the evidence, “[t]he burden of production then shifts to the employer to . . . provide ‘some legitimate, nondiscriminatory reason’ for the adverse employment action.” Sharif v. United Airlines, Inc., 841 F.3d 199, 203 (4th Cir. 2016) (quoting McDonnell Douglas, 410 U.S. at 802); see also Dobkin, 210 Md. 2024Under the McDonnell Douglas framework, once a plaintiff meets the initial burden of proving a prima facie case by a preponderance of the evidence, “[t]he burden of production then shifts to the employer to . . . provide ‘some legitimate, nondiscriminatory reason’ for the adverse employment action.” Sharif v. United Airlines, Inc., 841 F.3d 199, 203 (4th Cir. 2016) (quoting McDonnell Douglas, 410 U.S. at 802); see also Dobkin, 210 Md. | 1 | 1 |
Foster v. University of Maryland-Eastern Shoregreen2 sentences2022In Foster v. Univ. of Maryland-Eastern Shore, 787 F.3d 243 (4th Cir. 2015), the court held that in retaliation cases to which the McDonnell Douglas framework applies, the but-for causation requirement is satisfied because, even though less than but-for causation is required at the first stage, but-for causation is the essence of proof of pretext at the third stage. 2022In Foster v. Univ. of Maryland-Eastern Shore, 787 F.3d 243 (4th Cir. 2015), the court held that in retaliation cases to which the McDonnell Douglas framework applies, the but-for causation requirement is satisfied because, even though less than but-for causation is required at the first stage, but-for causation is the essence of proof of pretext at the third stage. | 1 | 1 |
Whittington v. The Nordam Group Incgreen2 sentences2016The relevant inquiry now is simply whether the evidence presented at trial supports a finding of liability.”); Whittington v. Nordam Group Inc., 429 F.3d 986, 993 (10th Cir.2005) (“We have repeatedly stated that juries are not to apply the McDonnell Douglas framework and that we are not concerned with plaintiffs proof of a prima facie case when we *506 review a jury verdict.”); Gibson v. Old Town Trolley Tours of Washington, D.C., Inc., 160 F.3d 177, 181 (4th Cir.1998) (“Once a case has proceeded through trial, however, whether the plaintiff ‘properly made out a prima facie case’ in the first 2016The relevant inquiry now is simply whether the evidence presented at trial supports a finding of liability.”); Whittington v. Nordam Group Inc., 429 F.3d 986, 993 (10th Cir.2005) (“We have repeatedly stated that juries are not to apply the McDonnell Douglas framework and that we are not concerned with plaintiffs proof of a prima facie case when we *506 review a jury verdict.”); Gibson v. Old Town Trolley Tours of Washington, D.C., Inc., 160 F.3d 177, 181 (4th Cir.1998) (“Once a case has proceeded through trial, however, whether the plaintiff ‘properly made out a prima facie case’ in the first | 1 | 1 |
cluster 759137green2 sentences2016The relevant inquiry now is simply whether the evidence presented at trial supports a finding of liability.”); Whittington v. Nordam Group Inc., 429 F.3d 986, 993 (10th Cir.2005) (“We have repeatedly stated that juries are not to apply the McDonnell Douglas framework and that we are not concerned with plaintiffs proof of a prima facie case when we *506 review a jury verdict.”); Gibson v. Old Town Trolley Tours of Washington, D.C., Inc., 160 F.3d 177, 181 (4th Cir.1998) (“Once a case has proceeded through trial, however, whether the plaintiff ‘properly made out a prima facie case’ in the first 2016The relevant inquiry now is simply whether the evidence presented at trial supports a finding of liability.”); Whittington v. Nordam Group Inc., 429 F.3d 986, 993 (10th Cir.2005) (“We have repeatedly stated that juries are not to apply the McDonnell Douglas framework and that we are not concerned with plaintiffs proof of a prima facie case when we *506 review a jury verdict.”); Gibson v. Old Town Trolley Tours of Washington, D.C., Inc., 160 F.3d 177, 181 (4th Cir.1998) (“Once a case has proceeded through trial, however, whether the plaintiff ‘properly made out a prima facie case’ in the first | 1 | 1 |
Williams v. Maryland Department of Human Resourcesgreen2 sentences2013In "failure to promote” actions, “[a]n appointing authority may promote from within an organizational unit a qualified candidate who is the incumbent in a position that is reclassified without requiring that the qualified candidate be on an eligible list for the particular classification....” Williams, 136 Md.App. at 175, n. 6 , 764 A.2d 351 (citing COMAR 06.01.01.13C. (2). 2013In "failure to promote” actions, “[a]n appointing authority may promote from within an organizational unit a qualified candidate who is the incumbent in a position that is reclassified without requiring that the qualified candidate be on an eligible list for the particular classification....” Williams, 136 Md.App. at 175, n. 6 , 764 A.2d 351 (citing COMAR 06.01.01.13C. (2). | 1 | 1 |
Joan M. Ennis v. The National Association of Business and Educational Radio, Incorporatedgreen2 sentences2000See Ennis, 53 F.3d at 59 . 7 . 2000See Ennis, 53 F.3d at 59 . 7 . | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Maryland. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Texas Department of Community Affairs v. Burdine
green
2 sentences2025The 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 . | 3 | 2003–2025 |
United States Postal Service Board of Governors v. Aikens
green
2 sentences2016In United States Postal Service Board of Governors v. Aikens, 460 U.S. 711, 715 , 103 S.Ct. 1478 , 75 L.Ed.2d 403 (1983), the United States Supreme Court explained that, pursuant to the McDonnell Douglas framework, once the employer has given a non-discriminatory reason for the adverse employment action and “done everything that would be required of him if the plaintiff had properly made out a prima facie case, whether the plaintiff really did so is no longer relevant.” At that point, the inquiry is whether, based on all the evidence presented, the employer intentionally discriminated against 2016In United States Postal Service Board of Governors v. Aikens, 460 U.S. 711, 715 , 103 S.Ct. 1478 , 75 L.Ed.2d 403 (1983), the United States Supreme Court explained that, pursuant to the McDonnell Douglas framework, once the employer has given a non-discriminatory reason for the adverse employment action and “done everything that would be required of him if the plaintiff had properly made out a prima facie case, whether the plaintiff really did so is no longer relevant.” At that point, the inquiry is whether, based on all the evidence presented, the employer intentionally discriminated against | 2 | 2003–2016 |
Romeka v. RadAmerica II, LLC
green
2 sentences2025At the causation stage of a retaliation case governed by the McDonnell Douglas framework, the employee “need not demonstrate but-for causation in her prima facie case; she needs to show only that the protected disclosure contributed in some way to the adverse employment action.” Romeka, 485 Md. at 327 . 2025At the causation stage of a retaliation case governed by the McDonnell Douglas framework, the employee “need not demonstrate but-for causation in her prima facie case; she needs to show only that the protected disclosure contributed in some way to the adverse employment action.” Romeka, 485 Md. at 327 . | 1 | 2025–2025 |
Department of Natural Resources v. Heller
green
2 sentences2023Indeed, just two sentences after the one that Ms. Romeka quotes from in Heller, we explained that, under the McDonnell Douglas framework, once the plaintiff makes the initial showing, then “the employer will only escape liability by proving that the employer would have taken the same personnel action in the absence of the protected disclosure.” Id. at 171 . 2023Indeed, just two sentences after the one that Ms. Romeka quotes from in Heller, we explained that, under the McDonnell Douglas framework, once the plaintiff makes the initial showing, then “the employer will only escape liability by proving that the employer would have taken the same personnel action in the absence of the protected disclosure.” Id. at 171 . | 1 | 2023–2023 |
William Price v. Tommy G. Thompson, Secretary, United States Department of Health and Human Services
green
2 sentences2023In Foster, the Fourth Circuit concluded that, in the context of a claim of unlawful retaliation, the McDonnell Douglas framework “already incorporates a but-for causation analysis.” Id. at 249 . 2023In Foster, the Fourth Circuit concluded that, in the context of a claim of unlawful retaliation, the McDonnell Douglas framework “already incorporates a but-for causation analysis.” Id. at 249 . | 1 | 2023–2023 |
Lewis v. Baltimore City Board of School Commissioners
green
2 sentences2022In Lewis v. Baltimore City Board of School Commissioners, 187 F.Supp.3d 588 (D. 2022In Lewis v. Baltimore City Board of School Commissioners, 187 F.Supp.3d 588 (D. | 1 | 2022–2022 |
Nerenberg v. RICA
green
2 sentences2013Our Court in Nerenberg, 131 Md.App. at 663 , 750 A.2d 655 , identified the McDonnell Douglas factors slightly different from the elements we use in the case at bar: "1) that [employee] was in a protected class; 2) she was discharged; 3) at the time of the discharge, she was performing her job at a level that met her employer’s legitimate expectations; and 4) her discharge occurred under circumstances that raise a reasonable inference of unlawful discrimination.” . 2013Our Court in Nerenberg, 131 Md.App. at 663 , 750 A.2d 655 , identified the McDonnell Douglas factors slightly different from the elements we use in the case at bar: "1) that [employee] was in a protected class; 2) she was discharged; 3) at the time of the discharge, she was performing her job at a level that met her employer’s legitimate expectations; and 4) her discharge occurred under circumstances that raise a reasonable inference of unlawful discrimination.” . | 1 | 2013–2013 |
Brandon v. Molesworth
green
2 sentences2003Burdine, supra, at 255 , 101 S.Ct. 1089 ; Killian, supra, at 68 , 716 A.2d 1071 ; Brandon, supra, at 188, 655 A.2d 1292 . 2003Burdine, supra, at 255 , 101 S.Ct. 1089 ; Killian, supra, at 68 , 716 A.2d 1071 ; Brandon, supra, at 188, 655 A.2d 1292 . | 1 | 2003–2003 |
Killian v. Kinzer
green
2 sentences2003Burdine, supra, at 255 , 101 S.Ct. 1089 ; Killian, supra, at 68 , 716 A.2d 1071 ; Brandon, supra, at 188, 655 A.2d 1292 . 2003Burdine, supra, at 255 , 101 S.Ct. 1089 ; Killian, supra, at 68 , 716 A.2d 1071 ; Brandon, supra, at 188, 655 A.2d 1292 . | 1 | 2003–2003 |
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.
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.