In the 1982 case United States Postal Service Board of Governors v. Aikens, the Supreme Court ruled that once a plaintiff in a discrimination lawsuit has made out a prima facie case of racial discrimination and the defendant has responded with evidence of legitimate, non-discriminatory reasons for its actions, it is not necessary to continue using the McDonnell Douglas Corp. v. Green framework (a legal test designed to determine whether there was illegal employment discrimination). Instead, at this point in proceedings, "the factual inquiry proceeds to a new level of specificity." The court held that if both parties have met their initial burdens under McDonnell Douglas Corp., then courts should simply ask whether an illegal discriminatory purpose was a motivating factor behind defendant's action against plaintiff. In this particular case involving Mr. Aikens who alleged racial bias by his employer - USPS Board Of Governors - he had established his prima facie claim and USPS had provided non-discriminatory reasons for its decisions regarding him; thus further application of McDonnell Douglas framework wasn't required according to SCOTUS.

In the dissenting opinion for United States Postal Service Board of Governors v. Aikens, Justice Thurgood Marshall argued that the majority's decision to dismiss Aikens' racial discrimination claim was premature and inappropriate. He contended that there were still unresolved factual disputes regarding whether or not race had been a factor in the employment decisions made by USPS. The lower courts should have been allowed to fully explore these issues before any judgement could be rendered on their merits. Furthermore, he criticized the majority for shifting focus from determining if discrimination occurred to evaluating how well USPS defended against such allegations - an approach which he believed undermined Title VII’s purpose of eradicating workplace discrimination.