Footnote 77

At this stage, the plaintiff's burden "is not onerous." Burdine, 450 U.S. at 253. In order to meet it, the plaintiff must show: (1) membership in a protected class (e.g., a racial minority); (2) qualification for the position at issue; (3) an adverse employment action, such as failure-to-hire or termination; and (4) continuing need for an employee with the plaintiff's qualifications, or replacement by another employee in circumstances creating an inference of discrimination. See id. at 253 n.6 (quoting McDonnell Douglas Corp., 411 U.S. at 802). Some courts phrase the fourth requirement more generally as follows: "the circumstances surrounding the action give rise to an inference of... discrimination." Abdu-Brisson v. Delta Air Lines, Inc., 239 F.3d 456, 468 (2d Cir.), cert. denied, 534 U.S. 993 (2001).