In Lehman, Secretary of the Navy v. Nakshian (1980), the U.S. Supreme Court ruled that federal government agencies are not required to go through a jury trial in civil cases under the Age Discrimination in Employment Act of 1967 (ADEA). The case was brought by Mrs. Louise Nakshian who alleged age discrimination against her employer, the Department of Navy. She requested a jury trial as part of her lawsuit but this request was denied by lower courts on grounds that sovereign immunity protected federal agencies from such trials unless explicitly waived by Congress. On appeal, the Supreme Court upheld these rulings stating that while ADEA does provide for jury trials against private employers, it does not expressly waive sovereign immunity for government employers and thus they cannot be subjected to jury trials without their consent.

In the dissenting opinion for Lehman, Secretary of the Navy v. Nakshian, Justice Brennan argued that Congress intended to grant jury trials in age discrimination cases when it passed the Age Discrimination in Employment Act (ADEA). He pointed out that while there is no explicit provision for a jury trial within ADEA itself, its legislative history and context suggest an intention to provide such rights. The majority's interpretation would mean that federal employees have fewer legal protections than their private sector counterparts - something he believed was inconsistent with Congressional intent. Furthermore, Brennan noted that denying a right to a jury trial could discourage victims of age discrimination from pursuing their claims due to fears about potential bias or prejudice from judges who are themselves often older individuals.