Ash v. Tyson Foods, Inc. Case Brief

Facts of the Case

African-American petitioners Ash and Hithon filed suit, alleging that respondent Tyson Foods, Inc., violated 42 U. S. C. § 1981 and Title VII of the Civil Rights Act of 1964 when it promoted two white males to fill shift manager positions sought by petitioners. During trial, the petitioner alleged that Tyson’s plant manager, who made the disputed hiring decisions, had referred on some occasions to each of the petitioners as “boy.” According to the petitioners, this was evidence of discriminatory animus.At the close of petitioners’ evidence, the District Court denied Tyson’s motion for judgment as a matter of law pursuant to Federal Rule of Civil Procedure 50(a). The jury found for petitioners. After trial, Tyson renewed its motion under Rule 50(b). The District Court granted that motion and, in the alternative, ordered a new trial under Rule 50(c). The Eleventh Circuit affirmed the grant of the Rule 50(b) motion as to Ash, deeming the trial evidence insufficient to show pretext, but reversed as to Hithon, finding enough evidence to go to the jury. It also affirmed the District Court’s Rule 50(c) remedy. Certiorari was granted.

Question

Under the Federal Employees Health Benefits Act of 1959, are suits brought by insurers against beneficiaries to recoup medical expenses heard in federal or state court?

CONCLUSION

“No and Yes. In an anonymous and unanimous per curiam opinion, the Court ruled that the Eleventh Circuit had made two separate errors in its decision. First, the Court found the Circuit Court’s “jump off the page and slap you in the face” image to be “unhelpful and imprecise as an elaboration of the standard.” The Court did not precisely define the standard for pretext claims based on superior qualifications or rule on whether Ash necessarily had established pretext. Second, the Court held that while the word “boy” is not always evidence of racism, it not always benign either. The meaning depends “on various factors including context, inflection, tone of voice, local custom, and historical usage,” and not on the presence of racial modifiers like “black” or “white.” The Circuit Court’s decision was reversed, and the Circuit Court was instructed to determine whether the errors were essential to the outcome of the case.”

Case Information

Citation: 546 US 454 (2006)
Decided: Feb 21, 2006
Case Brief: 2006