In a win for employers throughout California and across the country, a recent court decision shows that an “honest belief” continues to be an effective defense for employers responding to employment discrimination claims. In an employment law context, the “honest belief” rule focuses on what a decision-maker honestly believed the facts to be and whether that belief provides a legitimate, non-discriminatory reason for an employment decision and not on the accuracy of the underlying facts asserted by an employer.
In the recent case, it was the honest belief of a Wal-Mart manager that ended up protecting the company from an age discrimination lawsuit.
The Honest Belief Defense
Under the honest belief rule, employers facing a discrimination lawsuit may avoid a finding that the claimed nondiscriminatory reason was a pretext designed to mislead if the employer can show its reasonable reliance on the particular facts that were before it at the time the decision was made.
In the case at hand, the facts showed that Wal-Mart’s employment policy called for an employee to be terminated after four disciplinary actions. A store manager adhered to company protocol when he terminated an employee after she violated a workplace safety rule that resulted in a fourth disciplinary action.
In response to her termination, the disgruntled former employee asserted that she had learned from a co-worker several weeks before she was fired that the manager wanted her gone and was “looking for any excuse they could find to get [her] out of the store.” As a result, the ex-employee argued, some of the disciplinary actions should have been disregarded because they were the product of unlawful discrimination by her managers. The district court disagreed, indicating that the plaintiff proved unsuccessful in establishing that Wal-Mart’s stated nondiscriminatory reason for her discharge was pretextual.
Upon appeal, the Court of Appeals confirmed the lower court’s ruling. Referring to Wal-Marts’ “honest belief,” the court concluded that the plaintiff failed to present evidence calling into question Wal-Mart’s stated reason for terminating her, namely, her accumulation of four disciplinary actions.
For more information on the honest belief rule as a defense to an employment claim, contact experienced business attorney Drew E. Pomerance today.