Sprint/United Management Co. v. Mendelsohn
552 U.S. 379, 170 L. Ed. 2d 1, 2008 U.S. LEXIS 2195 (2008)
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Rule of Law:
Testimony from other employees alleging discrimination by supervisors who were not involved in the adverse employment action against the plaintiff is neither per se admissible nor per se inadmissible. Its admissibility must be determined by the district court on a case-by-case basis through a fact-intensive inquiry under Federal Rules of Evidence 401 and 403.
Facts:
- Ellen Mendelsohn was employed by Sprint/United Management Company (Sprint) from 1989 until 2002.
- In 2002, Sprint terminated Mendelsohn's employment as part of a companywide reduction in force.
- Mendelsohn alleged that her direct decision-making supervisor, Paul Reddick, terminated her because of her age.
- To support her claim, Mendelsohn sought to introduce testimony from five other former Sprint employees who also claimed they experienced age discrimination.
- None of these five potential witnesses had worked in Mendelsohn's department.
- Crucially, none of the five witnesses had worked under Mendelsohn’s supervisors or in her chain of command.
Procedural Posture:
- Ellen Mendelsohn filed an age discrimination lawsuit against Sprint in the U.S. District Court (trial court).
- Before trial, Sprint filed a motion in limine to exclude the testimony of other former employees who were not 'similarly situated' to Mendelsohn.
- The District Court granted Sprint's motion, limiting Mendelsohn to presenting evidence only from employees who had the same decision-maker and whose termination was close in time to hers.
- Following a trial on the merits, a jury returned a verdict in favor of Sprint.
- Mendelsohn (as appellant) appealed the evidentiary ruling to the U.S. Court of Appeals for the Tenth Circuit.
- The Court of Appeals (intermediate appellate court) reversed the District Court's decision, finding it had abused its discretion by applying a per se rule of exclusion, and remanded for a new trial.
- The U.S. Supreme Court granted a writ of certiorari at the request of Sprint (as petitioner).
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Issue:
In an age discrimination lawsuit, is testimony from other employees about discrimination by supervisors who played no role in the plaintiff's termination per se inadmissible under the Federal Rules of Evidence?
Opinions:
Majority - Justice Thomas
No. Evidence of discrimination by other supervisors is not per se inadmissible; its admissibility depends on a case-specific assessment of relevance and prejudice under Federal Rules of Evidence 401 and 403. The Court of Appeals erred by concluding the District Court applied a per se rule of inadmissibility and by then conducting its own evidentiary analysis. The proper course for the appellate court, faced with an ambiguous evidentiary ruling, was to remand the case to the District Court for clarification and for that court to conduct the proper balancing test in the first instance. District courts are afforded broad discretion in making evidentiary rulings, as they are in the best position to assess the probative value and potential for unfair prejudice of evidence within the context of a specific case. Such fact-intensive inquiries are not suitable for broad per se rules.
Analysis:
This decision clarifies the standard for admitting 'me too' evidence in employment discrimination cases, rejecting a categorical, bright-line rule in favor of a flexible, context-specific approach. It empowers and entrusts trial court judges to weigh the specific facts of each case when determining if testimony from other employees about other managers is relevant and not unduly prejudicial. The ruling reinforces the highly deferential standard of review for evidentiary decisions and guides appellate courts to remand cases for clarification when a trial court's reasoning is unclear, rather than substituting their own judgment.
