McDonnell Douglas burden-shifting framework (Maine) · Go Syfert
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McDonnell Douglas burden-shifting framework in Maine

7 Maine opinions name it 2 courts 2004–2021 1 in the last five years

The cases below were cited by Maine 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 (4)

CaseFollowedCited
McDonnell Douglas Corp. v. Greengreen
scotus · 1973 · cited in 2 Maine opinions naming this issue, 2011–2018
2 sentences

2018McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802-05 (1973); Doyle v. Dep't of Human Servs., 2003 ME 61 , ,r 14, 824 A.2d 48 .

2011Id. (citing McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802-805 (1973)); see Doyle, 2003l\1E 61, <]I 14, 824 A.2d 48 .

22
Gerard Brady v. Cumberland Countygreen
me · 2015 · cited in 3 Maine opinions naming this issue, 2016–2021
2 sentences

2017Although claims brought under the WPA originally applied the McDonnell Douglas burden shifting framework to the summary judgment stage, the Law Court has since dispensed 4 with this requirement, holding that the parties to such actions "are held to the same standard as in all other cases." Brady v. Cumberland Cnty., 2015 ME 143 , ,r 39, 126 A.3d 1145 .

2017Although claims brought under the WPA originally applied the McDonnell Douglas burden shifting framework to the summary judgment stage, the Law Court has since dispensed 4 with this requirement, holding that the parties to such actions "are held to the same standard as in all other cases." Brady v. Cumberland Cnty., 2015 ME 143 , ,r 39, 126 A.3d 1145 .

13
Doyle v. Department of Human Servicesgreen
me · 2003 · cited in 2 Maine opinions naming this issue, 2011–2018
2 sentences

2018McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802-05 (1973); Doyle v. Dep't of Human Servs., 2003 ME 61 , ,r 14, 824 A.2d 48 .

2018McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802-05 (1973); Doyle v. Dep't of Human Servs., 2003 ME 61 , ,r 14, 824 A.2d 48 .

12
Buntin v. City of Bostongreen
ca1 · 2017 · cited in 1 Maine opinions naming this issue, 2021–2021
2 sentences

2021Buntin v. City of Boston, 857 F.3d 69, 70 (1st Cir. 2017). 7 It's possible that the Law Court would eliminate the McDonnell Douglas burden-shifting framework in this case as it has for summary judgment motions in retaliation claims made under the Maine Whistleblowers' Protection Act.

2021Buntin v. City of Boston, 857 F.3d 69, 70 (1st Cir. 2017). 7 It's possible that the Law Court would eliminate the McDonnell Douglas burden-shifting framework in this case as it has for summary judgment motions in retaliation claims made under the Maine Whistleblowers' Protection Act.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (4)

CaseCitedYears
DiCentes v. Michaud green
me · 1998
2 sentences

2015Goodall Hosp., 2013 ME 33 , 3 Brady has not appealed the summary judgment issued in favor of Joyce and Gagnon, or the summary judgment issued in favor of the County on the remaining counts of his complaint against the County. 8 ¶ 15, 66 A.3d 7 (applying the McDonnell Douglas burden-shifting analysis to a summary judgment motion); DiCentes v. Michaud, 1998 ME 227, ¶¶ 14-17 , 719 A.2d 509 (applying the McDonnell Douglas burden-shifting analysis to the trial context).

2015Goodall Hosp., 2013 ME 33 , 3 Brady has not appealed the summary judgment issued in favor of Joyce and Gagnon, or the summary judgment issued in favor of the County on the remaining counts of his complaint against the County. 8 ¶ 15, 66 A.3d 7 (applying the McDonnell Douglas burden-shifting analysis to a summary judgment motion); DiCentes v. Michaud, 1998 ME 227, ¶¶ 14-17 , 719 A.2d 509 (applying the McDonnell Douglas burden-shifting analysis to the trial context).

22004–2015
Bhatti v. Trustees of Boston University green
ca1 · 2011
1 sentence

2021(Pl.'s Compl.1174-82.) Absent direct evidence of discriminatio~ the McDonnell Douglas burden-shifting framework has been used to evaluate a Section 1981 claim.7 Bhatti, 659 F.3d at 70 ; 5 42 U.S.C. § 1981 (a) states that "[a]ll persons within the jurisdiction of the United States shall have the same right in every State and Territory to make and enforce contracts, to sue, be parties, give evidence, and to the full and equal benefit of all laws and proceedings for the security of persons and property as is enjoyed by white citizens, and shall be subject to like punishment, pains, penalties, tax

12021–2021
Claire Trott v. H.D. Goodall Hospital green
me · 2013
2 sentences

2015Goodall Hosp., 2013 ME 33 , 3 Brady has not appealed the summary judgment issued in favor of Joyce and Gagnon, or the summary judgment issued in favor of the County on the remaining counts of his complaint against the County. 8 ¶ 15, 66 A.3d 7 (applying the McDonnell Douglas burden-shifting analysis to a summary judgment motion); DiCentes v. Michaud, 1998 ME 227, ¶¶ 14-17 , 719 A.2d 509 (applying the McDonnell Douglas burden-shifting analysis to the trial context).

2015Goodall Hosp., 2013 ME 33 , 3 Brady has not appealed the summary judgment issued in favor of Joyce and Gagnon, or the summary judgment issued in favor of the County on the remaining counts of his complaint against the County. 8 ¶ 15, 66 A.3d 7 (applying the McDonnell Douglas burden-shifting analysis to a summary judgment motion); DiCentes v. Michaud, 1998 ME 227, ¶¶ 14-17 , 719 A.2d 509 (applying the McDonnell Douglas burden-shifting analysis to the trial context).

12015–2015
Cookson v. Brewer School Department green
me · 2009
1 sentence

2011Id. (citing McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802-805 (1973)); see Doyle, 2003l\1E 61, <]I 14, 824 A.2d 48 .

12011–2011

Statutes the citing opinions construe

ME § Me. Rev. Stat. tit. 26, § 833 (3)

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

TX 76 (2003–2026) CA 49 (1996–2026) MI 26 (1995–2025) MN 15 (1997–2025) OH 13 (2011–2025) TN 12 (2010–2018) IA 11 (2003–2025) WA 9 (1999–2026) NY 9 (2015–2023) NJ 8 (1998–2023) ME 7 (2004–2021) KY 6 (2011–2025) GA 6 (2013–2023) IL 5 (1998–2025) KS 4 (1994–2024) VT 4 (1995–2024) MO 4 (2007–2024) DC 4 (2004–2024) MD 4 (2021–2024) RI 3 (2005–2009) LA 3 (2010–2023) PA 2 (2003–2024) NC 2 (2017–2024) ID 2 (2008–2013) CT 2 (2021–2025) AZ 2 (2018–2023) SD 2 (2006–2015) UT 2 (2000–2025) NH 2 (2001–2019)

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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