Brown v. CSC Logic, Inc.
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
The Fifth Circuit identified that effect on Brown's test in Russell v. McKinney Hospital Venture. Brown's test for remarks offered as direct evidence and its same actor inference continue to be cited and applied.
37 later cases cite Brown v. CSC Logic, Inc.; 37 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 Brown v. CSC Logic, Inc.?
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
Abrogated
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The Supreme Court rejected the Fifth Circuit's use of Brown's restrictive remarks test to discount circumstantial evidence of age discrimination merely because comments were outside the direct context of termination.
Reeves v. Sanderson Plumbing Products, Inc. · Supreme Court of the United States · filed
In holding that the record contained insufficient evidence to sustain the jury’s verdict, the Court of Appeals misapplied the standard of review dictated by Rule 50. Again, the court disregarded critical evidence favorable to petitioner — - namely, the evidence supporting petitioner’s prima facie case and undermining respondent’s nondiscriminatory explanation. See 197 F. 3d, at 693-694. The court also failed to draw all reasonable inferences in favor of petitioner. For instance, while acknowledging “the potentially damning nature” of Chesnut’s age-related comments, the court discounted them on the ground that they “were not made in the direct context of Reeves’s termination.”
Read the full opinion on CourtListener →
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