Although the McDonnell Douglas case dealt with employee selection, the prima facie elements can be modified for application to other employment contexts such as termination, discipline, and compensation. Upon establishing a prima facie case, a presumption of employment discrimination is created. The burden of proof then shifts to the employer (defendant) for rebuttal. The employer may satisfy its burden of proof at this stage by articulating a legitimate nondiscriminatory reason for its actions or by proving that a protected category is a bona fide occupational qualification (BFOQ). Specifically, Title VII states that organizations may hire employees based upon “religion. Sex, or national origin in those certain instances where religion, sex, or national origin is a bona fide occupational qualification reasonably necessary to the normal operation of that particular business or enterprise.