Term: 2007
Docket: 06-1221
Sprint/united Management Company v. Ellen Mendelsohn
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06-1221 SPRINT/UNITED MANAGEMENT CO. V. MENDELSOHN DECISION BELOW: 466 F3d 1223 CERT. GRANTED 6/11/2007 QUESTION PRESENTED: This case presents a recurring question of proof in employment discrimination cases: whether a district court must admit “me, too” evidence - testimony, by nonparties, alleging discrimination at the hands of persons who played no role in the adverse employment decision challenged by the plaintiff. The Tenth Circuit panel majority held that a court commits reversible error by excluding “me, too” evidence. This decision conflicts with those of other circuits. Specifically, four circuits have held “me, too” evidence wholly irrelevant. Five circuits have held that “me, too” evidence may be excluded under Federal Rule of Evidence 403. Granting certiorari will resolve the conflict between the circuit courts of appeals on this important question of law. LOWER COURT CASE NUMBER: 05-3150
The U.S. Supreme Court case Sprint/United Management Company v. Ellen Mendelsohn, 2007 revolved around the admissibility of "me too" evidence in age discrimination lawsuits under the Age Discrimination in Employment Act (ADEA). Ellen Mendelsohn, a former employee of Sprint/United Management Company, alleged that she was laid off due to her age and sought to introduce testimonies from five other employees who claimed they were also victims of age discrimination by the company. The District Court ruled against admitting this evidence on grounds that these employees did not share a supervisor with Mendelsohn and their experiences were irrelevant to her case. However, the Tenth Circuit reversed this decision stating such evidences could be relevant depending upon certain factors like similarity of experiences etc., but it didn't provide clear guidance for future cases regarding when such evidences would be deemed relevant or not. The Supreme Court vacated and remanded the judgment back to lower courts for further consideration without providing any definitive rule about 'me too' evidence's relevancy.
In the dissenting opinion for Sprint/United Management Company v. Ellen Mendelsohn, Justice Clarence Thomas argued that the majority's decision was too vague and did not provide clear guidance to lower courts on how to handle similar cases in the future. He disagreed with their ruling that evidence of discrimination against other employees could be admissible if it supported a "reasonable inference" of discrimination against the plaintiff. Instead, he believed this standard was too subjective and would lead to inconsistent rulings across different jurisdictions. He also expressed concern about potential prejudice towards defendants if such evidence were allowed without strict limitations. Therefore, he proposed a more stringent rule: only allowing such evidence when there is specific proof that it directly relates to discriminatory actions taken against the plaintiff.
