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The Supreme Court on 2/26/02 unanimously held that an employment discrimination complaint is not required to allege facts constituting a prima facie case of discrimination under the framework of McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973). That framework, the Court noted, establishes an evidentiary standard, not a pleading requirement. Before discovery, the nature of the required prima facie case may be difficult to determine, and discovery could reveal direct evidence of discrimination that would render McDonnell Douglas altogether inapplicable. Further, requiring a heightened pleading standard is inconsistent with Federal Rule of Civil Procedure 8(a)(2), which requires only “a short and plain statement of the claim showing that the pleader is entitled to relief.” This decision is important to any employer subject to federal employment discrimination statutes.

The Second Circuit had ruled that merely stating that the employee was Hungarian in a workplace predominantly comprising French workers was a complaint with insufficient specificity to put his employer on notice of his discrimination claims. The court also ruled that an allegation that the company president wanted to "energize" his department was insufficient to raise an inference of age discrimination. The High Court reversed this ruling.