Harris v. City of Santa Monica

A bus driver working for the City of Santa Monica, was fired after she disclosed that she was pregnant and later sued the City for pregnancy discrimination. At trial, the City sought jury instructions on the mixed-motive affirmative defense. The trial court refused, and instead, instructed the jury that the City was liable for discrimination if Harris’ pregnancy was a motivating factor for the discharge even if the other matters may have contributed. The jury returned a verdict for Harris. The City appealed, arguing that the court’s refusal to instruct the jury as requested deprived it of a legitimate defense. The Court reversed and remanded the decision holding that under the mixed-motive defense, an employer is not liable for actions that were motivated by both discriminatory and non-discriminatory reasons if it can establish that the legitimate reason, on its own, would have induced it to make the same decision.