Ash v. Tyson Foods, Inc., 546 U.S. 454 (2006)

In Ash v. Tyson Foods, Inc., Anthony Ash and John Hithon, both African-American superintendents at a Tyson Foods poultry plant, sought promotions to two available shift manager positions. Instead, two white males were selected for the roles. Ash and Hithon alleged that this decision constituted racial discrimination, leading them to file a lawsuit under 42 U.S.C. §1981 and Title VII of the Civil Rights Act of 1964. The case was initially heard in the United States District Court for the Northern District of Alabama, where a jury found in favor of the plaintiffs, awarding them compensatory and punitive damages. However, Tyson Foods moved for judgment as a matter of law, which the District Court granted, overturning the jury's verdict and ordering a new trial for both plaintiffs. The case then proceeded to the United States Court of Appeals for the Eleventh Circuit, which affirmed the decision regarding Ash but reversed it concerning Hithon, allowing his case to go to a jury while also affirming the order for a new trial due to issues with the punitive damages awarded. The Eleventh Circuit's decision was based on its interpretation of the evidence presented, including comments made by Tyson's plant manager, who referred to the petitioners as "boy." The Court of Appeals concluded that this term alone did not demonstrate discriminatory intent, a determination that the Supreme Court found problematic. The Supreme Court ultimately vacated the Court of Appeals' judgment, indicating that the context of such language and the standard for assessing pretext in discrimination cases required further consideration.

Whether the Court of Appeals erred in its assessment of evidence regarding discriminatory intent and the standard for determining pretext in a race discrimination case under 42 U.S.C. §1981 and Title VII of the Civil Rights Act of 1964.

The judgment of the Court of Appeals is vacated, and the case is remanded for further proceedings consistent with this opinion.