O'Connor v. Consolidated Coin Caterers Corp.

116 S. Ct. 1307 (U.S. 1996); No. 95-354 (U.S. Apr. 1, 1996) ; Clearinghouse Number: 51109

Description

Employee Need Not Prove That He Was Replaced by a Worker Outside the Protected Class in Order to Establish Prima Facie Case of Age Discrimination

Abstract

The Supreme Court has held that petitioner need not prove that he was replaced by a worker under 40 in order to make a prima facie case under the Age Discrimination in Employment Act (ADEA). Petitioner had been employed by respondent employer for 12 years when, at age 56, he was fired. Claiming dismissal due to his age in violation of the ADEA, petitioner sued. The district court granted employer summary judgment. On appeal, the Fourth Circuit held that petitioner could establish a prima facie case under McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973), only if he could prove that (1) he was in the age group protected by the ADEA; (2) he was discharged or demoted; (3) at the time of his discharge or demotion, he was performing his job at a level that met his employer's legitimate expectations; and (4) after his discharge or demotion, he was replaced by someone of comparable qualifications outside the protected class. Since petitioner's replacement was 40 years old, the court of appeals found that he did not meet the last element of a prima facie case and affirmed his dismissal. Petitioner appealed. The Supreme Court held that there must be at least a logical connection between each element of the prima facie case and the illegal discrimination; the element of replacement by someone under 40 fails this requirement; the statute does not ban discrimination against employees because they are 40 or older-it bans discrimination against employees because of their age but limits the protected class to those who are 40 or older; that one person in the protected class lost out to another in the protected class is irrelevant so long as he lost out because of his age.

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Attorney Information
Docket Date
1970-01-01 06:00:00+00:00

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