General Dynamics Land Systems, Inc. v. Cline
157 L. Ed. 2d 1094, 540 U.S. 581, 2004 U.S. LEXIS 1623 (2004)
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Rule of Law:
The Age Discrimination in Employment Act of 1967 (ADEA) does not prohibit an employer from favoring an older employee over a younger one. The Act's protection is a one-way street, shielding older workers from discrimination that benefits younger workers, but not vice-versa.
Facts:
- In 1997, General Dynamics and the United Auto Workers union entered into a new collective-bargaining agreement.
- This agreement eliminated the company's obligation to provide post-retirement health benefits for most employees.
- However, the agreement created an exception, preserving these benefits for then-current employees who were at least 50 years old.
- A group of employees, led by Roger Cline, were between 40 and 49 years old at the time of the agreement.
- While these employees were over 40 and thus part of the age group protected by the ADEA, they were excluded from the retiree health benefits because they were under 50.
- As a result, a group of older workers (50 and over) received a benefit that a group of younger workers (40-49) did not.
Procedural Posture:
- Roger Cline and other affected employees filed a claim with the Equal Employment Opportunity Commission (EEOC).
- After informal settlement failed, Cline sued General Dynamics in the U.S. District Court for the Northern District of Ohio (a federal trial court), alleging a violation of the ADEA.
- The District Court dismissed the case, ruling that the ADEA does not permit claims of 'reverse age discrimination.'
- Cline, as appellant, appealed to the U.S. Court of Appeals for the Sixth Circuit.
- A divided panel of the Sixth Circuit (an intermediate appellate court) reversed the trial court's dismissal, holding that the ADEA's plain language prohibits such discrimination.
- General Dynamics, as petitioner, successfully petitioned the U.S. Supreme Court for a writ of certiorari to resolve a conflict among the circuit courts on this issue.
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Issue:
Does the Age Discrimination in Employment Act of 1967 (ADEA) prohibit an employer from favoring older employees over younger employees, when all affected employees are within the ADEA's protected class of individuals aged 40 and over?
Opinions:
Majority - Justice Souter
No. The Age Discrimination in Employment Act (ADEA) does not prohibit an employer from favoring older employees over younger ones. The text, structure, purpose, and history of the ADEA show that the statute was intended to protect relatively old workers from discrimination that works to the advantage of the relatively young, not the other way around. The Court's reasoning is based on the social context and legislative history of the Act, which focused exclusively on the problem of older workers being disadvantaged due to stereotypes about age and ability. The statute’s establishment of a protected class starting at age 40 further indicates its purpose was to shield older workers from competition from their juniors, as 'the enemy of 40 is 30, not 50.' The Court dismissed an EEOC regulation to the contrary as 'clearly wrong' and not entitled to deference, finding that standard methods of statutory interpretation, including an analysis of the common, idiomatic understanding of 'age discrimination,' resolve any ambiguity in the text.
Dissenting - Justice Scalia
Yes. The Court should have deferred to the Equal Employment Opportunity Commission (EEOC) regulation which explicitly states that the ADEA makes it unlawful for an employer to give preference because of age between individuals who are 40 and over. Because the statutory text is not unambiguous and the EEOC's interpretation is a reasonable one, the agency's authoritative conclusion should control. The majority improperly brushed aside this reasonable agency interpretation as 'clearly wrong' without sufficient justification.
Dissenting - Justice Thomas
Yes. The plain language of the ADEA, which forbids discrimination 'because of such individual’s age,' is not limited to discrimination against the old. This reading is supported by the use of the word 'age' in other parts of the statute and by an EEOC regulation. The majority invents a new tool of statutory interpretation—'social history'—to ignore the clear text and limit the statute’s protection to only the 'principal evil' Congress targeted. This approach is in direct conflict with how the Court has interpreted Title VII’s prohibitions on race and sex discrimination in cases like McDonald v. Santa Fe Trail Transp. Co., which held that statutory prohibitions on discrimination protect all individuals, not just the historically disadvantaged group.
Analysis:
This decision fundamentally defines the scope of the ADEA, establishing that it does not support claims of 'reverse' age discrimination. It solidifies the understanding that the Act is a remedial statute with a specific purpose: to protect older workers from adverse treatment favoring younger ones. The majority's reliance on 'social history' and legislative purpose over a purely textual analysis signals a purposivist approach to interpreting this specific statute, which the dissent argues is inconsistent with the Court's interpretation of other major antidiscrimination laws like Title VII. The ruling provides employers with clarity that they may offer benefits that favor older employees without violating the ADEA, potentially influencing the design of early retirement programs and other age-related benefits.
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