Term: 2007
Docket: 06-1505
Meacham v. Knolls Atomic Power Lab.
- Pro
06-1505 MEACHAM, ET AL V. KNOLLS ATOMIC POWER LAB., ET AL DECISION BELOW: 461 F3d 134 LIMITED TO QUESTION 1 PRESENTED BY THE PETITION EXPEDITED BRIEFING SCHEDULE JUSTICE BREYER TOOK NO PART CERT. GRANTED 1/18/2008 QUESTION PRESENTED: The Age Discrimination in Employment Act (ADEA) prohibits employment practices that have an unjustified disparate impact on older workers, Smith v. City of Jackson, Miss., 544 U.S. 22(2005), but also provides that it "shall not be unlawful for an employer . . . to take any action otherwise prohibited . . . where the differentiation is based on reasonable factors other than age." 29 U.S.C. § 623(f)(1). The questions presented are: 1. Whether an employee alleging disparate impact under the ADEA bears the burden of persuasion on the "reasonable factors other than age" defense, as held by the Second Circuit in this case in conflict with the decisions of other circuits and a regulation of the Equal Employment Opportunity Commission. 2. Whether respondents' practice of conferring broad discretionary authority upon individual managers to decide which employees to lay off during a reduction in force constituted a "reasonable factor other than age" as a matter of law. LOWER COURT CASE NUMBER: 02-7378, 02-7474
In the case of Meacham v. Knolls Atomic Power Lab (2007), the U.S. Supreme Court ruled that employers bear the burden of proof in age discrimination lawsuits under federal law, specifically when they claim their actions were based on "reasonable factors other than age" (RFOA). The case involved 31 employees who were laid off by Knolls Atomic Power Laboratory and sued for age discrimination after realizing that older workers had been disproportionately affected by these layoffs. The court held a 7-1 decision stating that it is up to employers to show that they used reasonable factors other than age in making employment decisions if they want to avoid liability for disparate impact claims under Age Discrimination Employment Act (ADEA). This ruling clarified an important aspect of ADEA, strengthening protections against potential discriminatory practices targeting older workers.
In the dissenting opinion for Meacham v. Knolls Atomic Power Lab., Justice David Souter argued that the majority's interpretation of the Age Discrimination in Employment Act (ADEA) was incorrect and overly burdensome on employees. He contended that employers should bear both production and persuasion burdens when justifying an employment practice causing disparate impact based on age, as is consistent with Title VII cases involving race or sex discrimination. The majority ruling required employees to prove that their employer’s justification for a layoff was unreasonable, which Souter believed placed too much burden on workers who might lack access to necessary information about business decisions. Instead, he suggested it would be more appropriate for courts to decide whether an employer’s reasons were reasonable after hearing arguments from both sides.
