O'Connor v. Consolidated Coin Caterers Corp.
517 U.S. 308 (1996)
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Rule of Law:
To establish a prima facie case of age discrimination under the Age Discrimination in Employment Act (ADEA), a plaintiff does not need to show they were replaced by someone outside the protected class (under age 40). The plaintiff must show they were replaced by a person substantially younger, as this is a more reliable indicator of age-based discrimination.
Facts:
- James O'Connor began his employment with Consolidated Coin Caterers Corporation in 1978.
- On August 10, 1990, Consolidated Coin Caterers Corporation terminated O'Connor's employment.
- At the time of his termination, O'Connor was 56 years old.
- Following his discharge, O'Connor was replaced by an individual who was 40 years old.
Procedural Posture:
- James O'Connor filed suit against Consolidated Coin Caterers Corporation in the U.S. District Court for the Western District of North Carolina, alleging a violation of the ADEA.
- The District Court granted summary judgment in favor of the employer, Consolidated Coin Caterers Corporation.
- O'Connor, as appellant, appealed the decision to the U.S. Court of Appeals for the Fourth Circuit.
- The Court of Appeals affirmed the District Court's judgment, holding that O'Connor failed to establish a prima facie case because his replacement was 40 years old and therefore within the protected class.
- The U.S. Supreme Court granted O'Connor's petition for certiorari.
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Issue:
Does a plaintiff alleging a violation of the Age Discrimination in Employment Act (ADEA) have to prove they were replaced by someone outside the protected age group (i.e., under 40 years old) to establish a prima facie case of discrimination under the McDonnell Douglas framework?
Opinions:
Majority - Justice Scalia
No. A plaintiff in an ADEA case does not need to show they were replaced by someone outside the protected class to establish a prima facie case. The ADEA prohibits discrimination 'because of an individual's age,' not because of their membership in the class of individuals aged 40 and over. The Court reasoned that the crucial element is whether the plaintiff lost their job because of their age. An inference of age discrimination arises not from the replacement being outside the protected class, but from the replacement being substantially younger than the plaintiff. For example, there is no greater inference of age discrimination when a 40-year-old is replaced by a 39-year-old than when a 56-year-old is replaced by a 40-year-old. Therefore, the fact that a replacement is substantially younger is a far more reliable and probative indicator of age discrimination than the arbitrary fact of whether the replacement is under 40.
Analysis:
This decision significantly clarifies the evidentiary standard for ADEA plaintiffs, making it easier to establish a prima facie case. By removing the rigid requirement that a replacement must be outside the protected class, the Court focused the inquiry on the more relevant factor of a substantial age difference. This prevents employers from defeating discrimination claims at the outset simply by replacing an older worker with a much younger one who happens to be over 40. The ruling ensures that the McDonnell Douglas framework is applied logically to age discrimination, focusing on the inference of age bias rather than an arbitrary class boundary.
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