Swierkiewicz v. Sorema N. A., 534 U.S. 506 (2002), was a case decided by the Supreme Court of the United States on February 26, 2002. The Court held that for complaints in employment discrimination cases, a plaintiff is not required to allege specific facts that establish a prima facie case as required by the McDonnell Douglas burden-shifting framework.[1][2]
In a unanimous decision delivered by Justice Thomas, the Court reversed, holding that “an employment discrimination complaint need not include such facts and instead must contain only ‘a short and plain statement of the claim showing that the pleader is entitled to relief.’ Fed. Rule Civ. Proc. 8(a)(2).”[6][2] The Court also stated that the required prima facie case in the McDonnell Douglas burden-shifting framework is a “flexible evidentiary standard” instead of a “rigid pleading requirement.”[7][2][3][8]
