Finding that the plaintiff had established "the easily-met burden of a prima facie case" the Sixth Circuit reversed the summary judgment entered by the district court and remanded Paula Brown's retaliation claim for trial in Paula Brown v. Lexington-Fayette Urban County Government, No 10-5846 (June 12, 2012). The Sixth Circuit also advised that the case "illustrates the inherent risk in limiting analysis to the prima facie stage of Title VII litigation."
The easily met burden of a prima facie case was described as follows:
At the prima facie stage of the litigation, however, the burden upon the plaintiff is minimal. See EEOC v. Avery Dennison Corp., 104 F3d 858, 861 (6th Cir 1997). "It is a burden easily met," Wrenn v Gould, 808 F2d 493, 500 (6th Cir 1987), and "is not onerous." Jackson v RKO Bottlers of Toledo, Inc., 743 F2d 370, 377 (6th Cir 1984). "All that is required at the prima facie stage is to demonstrate that she has a case, that the evidence is on her side." Avery Dennison Corp., 104 F3d at 861.
