In her deposition, Plaintiff maintained that she was waiting for an inventory control person to arrive from Honolulu. However, Plaintiff did not deny that she failed to follow Perreira's written instructions to her and missed the deadline.

Under the pattern-or-practice paradigm, a plaintiff must prove, by circumstantial or direct evidence, that an employer’s past actions evidence a pattern of illegal discrimination against a protected class. See, e.g., Hazelwood Sch. Dist. v. United States, 433 U.S. 299, 307, 97 S.Ct. 2736, 53 L.Ed.2d 768 (1977); Cooper v. Federal Reserve Bank, 467 U.S. 867, 876, 104 S.Ct. 2794, 81 L.Ed.2d 718 (1984) (citing International Bhd. of Teamsters v. United States, 431 U.S. 324, 326, 97 S.Ct 1843, 52 L.Ed.2d 396 (1977)).

Under the disparate impact paradigm, a plaintiff must prove statistically that a certain employment practice has a disparate impact on a protected class. See, e.g., Griggs v. Duke Power Co., 401 U.S. 424, 91 S.Ct. 849, 28 L.Ed.2d 158 (1971) (using statistics to demonstrate that an *378employer’s general intelligence test operated to discriminate against African Americans); see also Latinos Unidos De Chelsea En Accion (LUCHA) v. Secretary of Hous. & Urban Dev., 799 F.2d 774, 784 (1st Cir.1986) (“statistical disparity may be sufficient to establish a prima facie case of employment discrimination”). The focus of disparate impact discrimination claims is not on individual hiring and firing decisions, but rather on the impact that policies and procedures have on a certain class of individuals. See Griggs, 401 U.S. at 432, 91 S.Ct. 849.

See International Bhd. of Teamsters, 431 U.S. at 335-36 n. 15, 97 S.Ct. 1843 (describing disparate treatment discrimination as "the most easily understood type of discrimination. The employer simply treats some people less favorably than others because of their race, color, religion, sex, or national origin.”).

In Reeves v. Sanderson Plumbing Products, Inc., 530 U.S. 133, 120 S.Ct. 2097, 147 L.Ed.2d 105 (2000), the United States Supreme Court recently held that'a plaintiff's prima facie case of employment discrimination, as defined in McDonnell Douglas, combined with sufficient evidence for the trier of fact to disbelieve the employer’s proffered nondiscriminatory explanation, may permit the trier of fact to conclude that the employer intentionally discriminated. Id. at 2109 (emphasis added). The plaintiff need not always adduce additional evidence other than that used to rebut the employer’s explanation. Id. at 2108-09. The Court further stated, however, that: Id. The same-actor inference was not at issue in Reeves, but it would appear to qualify as "other evidence that supports the employer’s case and that properly may be considered on a motion for summary judgment as a matter of law.” Id.

Since the Fourth Circuit’s 1991 decision in Proud, subsequent adaptations of the same actor doctrine have expanded upon the doctrine’s original parameters as set forth in Proud. First, although Proud involved an age discrimination case, subsequent cases adapting the same actor doctrine have applied the doctrine in cases involving the Americans with Disabilities Act (ADA), 42 U.S.C. §§ 12201-12213 (1994), which prohibits discrimination on the basis of disability, and Title VII of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000e-2000e-17 (1994), which prohibits discrimination by covered employers on the basis of race, color, religion, gender or national origin. See Tyndall v. National Educ. Ctrs., Inc., 31 F.3d 209 (4th Cir.1994) (extending Proud inference to ADA context, strengthening terminology to "strong presumption”); Mitchell v. Data Gen. Corp., 12 F.3d 1310 (4th Cir.1993) (extending Proud inference to reduction-in-force situation and affirming summary judgment for employer); Amirmokri v. Baltimore Gas & Elec. Co., 60 F.3d 1126 (4th Cir.1995) (national origin); Buhrmaster v. Overnite Transp. Co., 61 F.3d 461, 464 (6th Cir.1995), cert. denied, 516 U.S. 1078, 116 S.Ct. 785, 133 L.Ed.2d 736 (1996) (gender); Jiminez v. Mary Washington College, 57 F.3d 369, 378 (4th Cir.1995) (race and national origin). Second, although the same actor doctrine was originally restricted to situations in which the same person did the hiring and firing, the requirement of a direct relationship among the hirer, the firer, and the employee has been significantly loosened. In many cases, the doctrine has been applied even where there have been multiple decisionmakers or when there has been ambiguity as to whether the same individual was involved in both actions. See, e.g., Amirmokri, 60 F.3d at 1130 (indicating that hirer-firer identity satisfied if the same company involved in both decisions); Birkbeck v. Marvel Lighting Corp., 30 F.3d 507, 513 (4th Cir.1994) (suggesting that a direct relationship between the individual hirer and the plaintiff is not necessary to establish the inference so long as the firing official has hired others in the plaintiff's protected class); Nieto v. L & H Packing Co., 108 F.3d 621, 623 (5th Cir.1997) (implicitly rejecting employee's contention disputing the identity of the hirer and firer and accepting employer’s argument that corporate decisions are often made by management groups); Lowe v. J.B. Hunt Transp., Inc., 963 F.2d 173, 174 (8th Cir.1992) (considering evidence that "same people” or “same company officials” hired and fired plaintiff in less than two years "compelling ... in light of the weakness of the plaintiff’s evidence otherwise”); but see Madel v. FCI Mktg., Inc., 116 F.3d 1247, 1253 (8th Cir.1997) (declining to infer nondiscrimination when derogatory comments made by plaintiff’s supervisor could have influenced employer’s decision to fire plaintiff). Third, the same actor inference has been raised in failure-to-promote and failure-to-hire *381situations. See, e.g., Hartsel v. Keys, 87 F.3d 795 (6th Cir.1996), cert. denied, [519 U.S. 1055,] 117 5.Ct. 683, [136 L.Ed.2d 608].(1997); Evans v. Technologies Applications & Serv. Co., 80 F.3d 954 (4th Cir.1996); Amirmokri, 60 F.3d at 1130; Thurman v. Yellow Freight Sys., Inc., 90 F.3d 1160 (6th Cir.), amended by 97 F.3d 833 (6th Cir.1996). - Fourth, although the time interval between the hiring and firing decisions was originally required to be “relatively short,” or "several months,” Proud, 945 F.2d at 796-97 (four months), subsequent cases have extended the time interval to up to seven years. See Buhrmaster, 61 F.3d at 462-64. See also, e.g., Crossmann v. Dillard Dep't Stores, Inc., 109 F.3d 457 (8th Cir.1997) (four years); Brown v. CSC Logic, Inc., 82 F.3d 651 (5th Cir.1996) (four-plus years). Fifth, although the same actor doctrine was originally termed a "strong inference,” Proud, 945 F.2d at 798, subsequent cases have termed the inference a “powerful inference,” "presumption,” and “strong presumption.” See Bradley, 104 F.3d at 270-71 (strong inference); Mitchell, 12 F.3d at 1318 (strong inference); Evans, 80 F.3d at 959 (powerful inference); Brown, 82 F.3d at 658 (presumption); Tyndall v. National Educ. Ctrs., Inc., 31 F.3d 209, 215 (4th Cir.1994). Although the words "inference” and "presumption” often are used interchangeably, the two words may have distinct implications in a given case. See, e.g., Anna Laurie Bryant & Richard A. Bales, Using the Same Actor "Inference” in Employment Discrimination Cases, 1999 Utah L.Rev. 255, 281 (1999). "An inference is a logical conclusion that a fact finder is permitted, but not required, to make based on circumstantial evidence. The fact finder may draw the inference or not, as its experience and the other evidence may move it." Id. (citing See Joel S. Hjelmaas, Stepping Back from the Thicket: A Proposal for the Treatment of Rebuttable Presumptions and Inferences, 42 Drake L.Rev. 427, 431 (1993), and Jerome A. Hoffman, Thinking About Presumptions: The "Presumption” of Agency from Ownership as Study Specimen, 48 Ala.L.Rev. 885, 892 (1997)).