The Supreme Court addressed VRRA's burden of proof standard in "Monroe v. Standard Oil Co.," 452 U.S. 459, 551, 559-560 (1981). The Court held that in order for a reservist/employee to prove that an employer violated the VRRA, the reservist/employee must show the employer's discriminatory actions against the reservist/employee were "motivated solely by reserve status." The Court's holding in Monroe resulted in the enactment of USERRA, which was written, in part, to overrule Monroe' burden of proof requirement. The burden of proof under USERRA today is much easier.