This Law Firm Publication by Foley Hoag LLP discusses the Massachusetts Supreme Judicial Court's decision in Bulwer v. Mount Auburn Hospital. This decision highlights the distinction between the burden of proof under federal law and Massachusetts law at summary judgment on an employment discrimination claim. To establish pretext under federal law, a plaintiff must prove that the employer’s reason for terminating an employee was false and that the real reason was unlawful discrimination. By contrast, under Massachusetts law, a plaintiff has a lower burden of proof and can defeat summary judgment merely by showing the employer's reason was false.