Combs v. Plantation Patterns
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
The Supreme Court rejected its categorical rule that a prima facie discrimination case plus evidence discrediting the employer's explanation always sends the claim to a jury. The Eleventh Circuit also rejected a prima facie qualification requirement stated in a Combs footnote. The two confirmed treatments are listed below; later opinions continue to apply other parts of Combs.
84 later cases cite Combs v. Plantation Patterns; 84 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.
Relying on Combs v. Plantation Patterns?
This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.
Treatments
Overruled in part
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The Supreme Court rejected Combs's categorical rule that a prima facie case and evidence discrediting an employer's explanation always create a jury issue.
Reeves v. Sanderson Plumbing Products, Inc. · Supreme Court of the United States · filed
Compare Kline v. TVA, 128 F. 3d 337 (CA6 1997) (prima facie ease combined with sufficient evidence to disbelieve employer’s explanation always creates jury issue of whether employer intentionally discriminated); Combs v. Plantation Patterns, 106 F. 3d 1519 (CA11 1997) (same), cert. denied, 522 U. S. 1045 (1998); ... This is not to say that such a showing by the plaintiff will always be adequate to sustain a jury’s finding of liability. Certainly there will be instances where, although the plaintiff has established a prima facie case and set forth sufficient evidence to reject the defendant’s explanation, no rational factfinder could conclude that the action was discriminatory.
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Criticized
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The Eleventh Circuit rejected the prima facie qualification requirement stated in a Combs footnote, while distinguishing that statement from holdings inconsistent with the governing rule.
Walker v. Mortham · Eleventh Circuit · filed
Since Perryman, we have several times included the "lesser or equal qualifications" prong in our articulation of a prima facie case for discrimination in failure to promote. See e.g., Carter v. Three Springs Residential Treatment, 132 F.3d 635, 642 (11th Cir.1998); Evans v. McClain of Ga., Inc., 131 F.3d 957, 963 (11th Cir.1997); Combs v. Plantation Patterns, 106 F.3d 1519, 1539 n. 11 (11th Cir.1997); ... In only two of these cases, however, does the Perryman formulation give rise to a holding inconsistent with recognition of the Crawford prima facie standard as the law of the circuit .23 ... In light of our own precedent and the decisions by the Supreme Court in Burdine and Patterson, we hold that district court in this case erred in imposing as part of the prima facie case a requirement that each plaintiff establish that the successful applicant for his or her coveted position was less than or equally qualified to hold the position.
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