In the case of St. Mary's Honor Center v. Melvin Hicks, 1992, the U.S Supreme Court ruled that a plaintiff alleging racial discrimination under Title VII of the Civil Rights Act must not only prove that an employer’s stated reason for adverse employment action was pretextual but also provide evidence to support their claim of discriminatory intent. The court held in favor of St. Mary's Honor Center with a majority decision stating that showing an employer’s explanation is false does not necessarily mean it concealed a discriminatory purpose; hence additional proof is required to establish unlawful discrimination. Melvin Hicks had claimed he was fired from his job at St. Mary's Honor Center due to racial bias and argued successfully in lower courts by proving inconsistencies in his employers' reasons for termination were enough to infer illegal motive behind their actions. However, this ruling by Supreme Court raised the bar on what plaintiffs need to demonstrate when claiming workplace discrimination - they must now show both falsity and prejudice as separate elements rather than one implying another automatically.

In the dissenting opinion for St. Mary's Honor Center v. Melvin Hicks, Justice Souter argued that the majority had unnecessarily complicated discrimination law by requiring a plaintiff to prove discriminatory intent in every case, even after establishing a prima facie case of discrimination and showing an employer’s explanation was pretextual. He contended that this additional burden on plaintiffs could deter victims from pursuing legitimate claims and would make it more difficult for courts to identify true instances of discrimination. Furthermore, he criticized the majority's reliance on McDonnell Douglas Corp v Green (1973), arguing they misinterpreted its principles which were meant as guides rather than rigid rules. In his view, once a plaintiff has shown an employer’s reason is false or unworthy of belief, no further proof should be required; such evidence alone should suffice to support an inference of intentional discrimination.