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Yu v. Idaho State University

United States District Court, D. Idaho

February 8, 2019

JUN YU, Plaintiff,
v.
IDAHO STATE UNIVERSITY, Defendant.

          MEMORANDUM DECISION AND ORDER RE: PLAINTIFF'S MOTION IN LIMINE RE: MCDONNELL-DOUGLAS PROCEDURE (DKT. 83)

          Honorable Ronald E. Bush Chief U.S. Magistrate Judge

         This decision resolves Plaintiff's Motion in Limine Requesting the Court to Order the Application at Trial of the McDonnell Douglas v. Green Procedure and Framework (Dkt. 83).

         BACKGROUND Plaintiff Jun Yu alleges that Defendant Idaho State University deliberately and unlawfully discriminated against him due to his national origin in violation of Title VI of the 1964 Civil Rights Act, 42 U.S.C. §§ 2000d et. seq. FAC ¶ 353 (Dkt. 41). In this motion, Plaintiff requests that the Court adhere to the procedural order and evidentiary proof and burden-shifting framework established by the United States Supreme Court in McDonnell-Douglas v. Green, 411 U.S. 792 (1973). Plaintiff also requests that he be allocated two-thirds of trial time, rather than the previously-ordered one-half.

         LEGAL STANDARDS

         The McDonnell-Douglas framework consists of a three-step process setting forth the basic allocation of burdens and order of presentation of proof in a Title VII case alleging discriminatory treatment. Texas Dep't of Comm. Affairs v. Burdine, 450 U.S. 248, 252 (1981). The process also applies in Title VI cases such as the one at bar. Rashdan v. Geissberger, 764 F.3d 1179, 1183 (9th Cir. 2014). Under the process,

First, the plaintiff has the burden of proving by the preponderance of the evidence a prima facie case of discrimination. Second, if the plaintiff succeeds in proving the prima facie case, the burden shifts to the defendant to articulate some legitimate, nondiscriminatory reason for the employee's rejection. Third, should the defendant carry this burden, the plaintiff must then have an opportunity to prove by a preponderance of the evidence that the legitimate reasons offered by the defendant were not its true reasons, but were a pretext for discrimination.

Burdine, 450 U.S. at 252-253 (citations and internal quotation marks omitted).

         The McDonnell-Douglas “legal proof structure is a tool to assist plaintiffs at the summary judgment stage so that they may reach trial.” Costa v. Desert Palace, Inc., 299 F.3d 838, 855 (9th Cir. 2002) (en banc), aff'd, 539 U.S. 90 (2003). “[W]hen the defendant fails to persuade the district court to dismiss the action for lack of a prima facie case, and responds to the plaintiff's proof by offering evidence of the reason for the plaintiff's rejection, the fact finder must then decide whether the rejection was discriminatory within the meaning of Title VII. At this stage, the McDonnell-Burdine presumption drops from the case and the factual inquiry proceeds to a new level of specificity.” United States Postal Serv. Bd. v. Aikens, 460 U.S. 711, 714-715 (1983).

         “The prima facie case method established in McDonnell Douglas was never intended to be rigid, mechanized, or ritualistic. Rather, it is merely a sensible, orderly way to evaluate the evidence in light of common experience as it bears on the critical question of discrimination. Where the defendant has done everything that would be required of him if the plaintiff had properly made out a prima facie case, whether the plaintiff really did so is no longer relevant.” Id. at 715. Nothing about the framework requires that trial courts treat discrimination differently from other ultimate questions of fact. Id. Nor should courts “make their inquiry even more difficult by applying legal rules which were devised to govern the allocation of burdens and order of presentation of proof in deciding this ultimate question.” Id. (citation and internal quotation marks omitted).

         It is error to charge the jury with the elements of the McDonnell-Douglas prima facie case, because the technical elements of the presumptions and shifting burdens have significant potential to confuse juries. Sanghvi v. City of Claremont, 328 F.3d 532, 540-541 (9th Cir. 2003) (citing Costa, 299 F.3d at 855). Indeed, “[r]egardless of the method chosen to arrive at trial, it is not normally appropriate to introduce the McDonnell Douglas burden-shifting framework to the jury. At that stage, the framework unnecessarily evades the ultimate question of discrimination vel non.” Costa, 299 F.3d at 855-856 (citation, footnote, and internal quotation marks omitted).

         DISCUSSION

         Plaintiff wants trial to proceed in four phases, comprised of (1) Plaintiff's presentation of his prima facie case of discrimination; (2) Defendant's presentation of its claimed legitimate reasons for dismissing Plaintiff; (3) Plaintiff's presentation to demonstrate that Defendant's claimed reasons were pretextual; and (4) Plaintiff's presentation of rebuttal evidence in response to Defendant's presentation of evidence in the second phase. Plf.'s Mem. ISO 2-3 (Dkt. 83-1). Plaintiff cites no authority for the proposition that such a phased approach at trial has been implemented by a trial court or upheld by a reviewing court. The Court has not independently identified any cases supporting such an approach.

         Federal Rule of Evidence 611(a) provides that the court should exercise reasonable control over the mode and order of examining witnesses and presenting evidence so as to make those procedures effective for determining the truth and avoid wasting time. In an exercise of discretion under such Rule, the Court will deny Plaintiff's motion as to the order of proof and related trial procedures.

         The McDonnell-Douglas burden-shifting framework is best used in pre-trial proceedings to assess whether Plaintiff can establish a prima facie case of discrimination. Plaintiff's burden at trial is not merely to establish such a prima facie case, but to persuade the jury on the ultimate issue of discrimination. Plaintiff has already cleared the hurdles of motion practice so that he may reach trial on the merits, as the Court previously ruled that Plaintiff ...


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