Must a plaintiff's complaint in an employment discrimination case allege specific facts that establish each element of the McDonnell Douglas prima facie case to survive a motion to dismiss?

Akos Swierkiewicz, a 53-year-old Hungarian native, worked as senior vice president and chief underwriting officer at Sorema N.A., a reinsurance company. After nearly six years, CEO François M. Chavel demoted Swierkiewicz and transferred his responsibilities to Nicholas Papadopoulo, a 32-year-old French national. Swierkiewicz alleges that Papadopoulo was less experienced and qualified for the position.

Following his demotion, Swierkiewicz claims he was isolated, excluded from decision-making processes, and denied opportunities within the company. After unsuccessful attempts to address his concerns, Swierkiewicz was terminated in April 1997 when he refused to resign. He subsequently filed a lawsuit against Sorema N.A., alleging that his termination was based on national origin discrimination in violation of Title VII and age discrimination in violation of the Age Discrimination in Employment Act (ADEA).

Swierkiewicz initiated a lawsuit in the United States District Court for the Southern District of New York. The district court dismissed the complaint, ruling that it failed to adequately allege a prima facie case of discrimination. Swierkiewicz then appealed to the United States Court of Appeals for the Second Circuit. The Second Circuit affirmed the district court's dismissal, applying its precedent that required plaintiffs in employment discrimination cases to allege facts constituting a prima facie case under the McDonnell Douglas framework. Subsequently, the Supreme Court granted certiorari to address a circuit split regarding the appropriate pleading standard for employment discrimination cases.

(Thomas, J.)

No. A plaintiff's complaint in an employment discrimination case need not allege specific facts establishing each element of the McDonnell Douglas prima facie case to survive a motion to dismiss. The McDonnell Douglas framework is an evidentiary standard, not a pleading requirement. Federal Rule of Civil Procedure 8(a)(2) governs pleading standards in civil actions, requiring only "a short and plain statement of the claim showing that the pleader is entitled to relief." This simplified notice pleading standard applies to all civil actions with limited exceptions, and imposing a heightened pleading standard for employment discrimination cases would conflict with this rule. The McDonnell Douglas framework does not apply in every employment discrimination case, making it inappropriate to require plaintiffs to plead facts establishing a prima facie case at the outset. Precedents such as Conley v. Gibson and Leatherman v. Tarrant County Narcotics Intelligence and Coordination Unit support this interpretation of pleading standards. Requiring specific facts to establish a prima facie case at the pleading stage would impose a heightened pleading standard that is inconsistent with the Federal Rules and Supreme Court precedent. The notice pleading standard ensures that plaintiffs have a fair opportunity to present their claims, while defendants can seek more detailed factual allegations through other pretrial mechanisms such as motions for a more definite statement or discovery.