Executive Summary: On March 21, 2019, in Lewis v. Union City, No. 15-11362, the U.S. Court of Appeals for the Eleventh Circuit (1) clarified the proper standard for the comparator analysis in intentional discrimination cases under the McDonnell Douglas burden-shifting framework and (2) held that a qualitative comparator analysis remains part of the initial prima facie stage of the McDonnell Douglas framework.
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