Term: 2018
Docket: 17-587
Mount Lemmon Fire District v. Guido
- Pro
17-587 MOUNT LEMMON FIRE DISTRICT V. GUIDO DECISION BELOW: 859 F.3d 1168 CERT. GRANTED 2/26/2018 QUESTION PRESENTED: The Age Discrimination in Employment Act (ADEA) defines certain private and public entities as "employers" and prohibits them from discriminating against employees because of their age. The Act applies to private entities only if they had "twenty or more employees for each working day in each of twenty or more calendar weeks in the current or preceding calendar year." 29 U.S.C. § 630(b). The question presented is: Under the ADEA, does the same twenty-employee minimum that applies to private employers also apply to political subdivisions of a State, as the Sixth, Seventh, Eighth, and Tenth Circuits have held, or does the ADEA apply instead to all State political subdivisions of any size, as the Ninth Circuit held in this case? LOWER COURT CASE NUMBER: 15-15030
The U.S. Supreme Court case Mount Lemmon Fire District v. Guido in 2018 revolved around the interpretation of the Age Discrimination in Employment Act (ADEA). The plaintiffs, John Guido and Dennis Rankin, were two oldest full-time firefighters who were laid off by Arizona's Mount Lemmon Fire District due to budget cuts. They sued alleging age discrimination under ADEA which forbids employers from discriminating against any individual aged 40 or older because of their age. However, the fire district argued that it was too small to qualify as an employer under ADEA since it had less than 20 employees - a threshold for private sector companies. The Supreme Court unanimously ruled in favor of Guido and Rankin stating that state and local governments are "employers" regardless of their size under ADEA unlike private sector businesses where a minimum employee count is required.
In the case of Mount Lemmon Fire District v. Guido, there was no dissenting opinion as the decision was unanimous. The Supreme Court ruled 8-0 that state and local governments can be held liable for age discrimination regardless of their size. This ruling clarified a discrepancy in the Age Discrimination in Employment Act (ADEA), which sets different rules for private sector employers and public sector employers on this issue. In particular, it states that all federal, state, and local government entities are "employers" under ADEA irrespective of how many employees they have while private-sector employers must have at least 20 employees to fall within its purview.
