Rao S. Mandalapu v. Temple University Hospital, et al.

Title VII of the Civil Rights Act of 1964 (42 U.S.C. §§ 2000e-2-3) and the Civil Rights Act of 1866 (42 U.S.C. § 1981) prevent discrimination and retaliation in the workplace. Twenty years ago, this Court clarified, in Reeves v. Sanderson Plumbing, that a plaintiff can prevail by presenting a prima facie case along with pretext of the employer’s articulated reason. Such a showing would prevent a defendant employer from obtaining summary judgment. Since, then appellate courts have interpreted this standard differently, sometimes requiring “animus” or additional evidence beyond that as articulated in Reeves. The question presented is: At the summary judgment stage, is it necessary for a plaintiff to show discriminatory or retaliatory “animus” against a protected category in order to prevent dismissal?