Issue
The United States Supreme Court recently considered the issue of whether the Age Discrimination in Employment Act (ADEA) forbids discrimination against younger workers in favor of older workers. (General Dynamics Land Systems, Inc. v. Cline (2004 Daily Journal, D.A.R. 2305 U.S., February 24, 2004)
Facts
A 1997 collective bargaining agreement between General Dynamics and the United Auto Workers eliminated health benefits to retired employees, except as to then-current workers at least 50 years old. Workers that were between the ages of 40 and 49 sued, claiming the agreement violates the ADEA’s prohibition against age discrimination. The U.S. Court of Appeals agreed with the younger workers, and the Supreme Court agreed to review its decision.
Supreme Court Decision
The ADEA prohibits discrimination “because of [an] individual’s age.” While recognizing that this language could be broadly read to prohibit all discrimination based on age (including discrimination in favor of older workers over younger workers), the Supreme Court nonetheless concluded that “the text, structure, purpose, and history of the ADEA, along with its relationship to other federal statutes, [show] that the statute does not mean to stop an employer from favoring an older employee over a younger one.”
The Court first noted that the legislative history of the ADEA focused on disadvantages to older individuals in employment. Furthermore, the introductory provisions of the ADEA refer to the effects of age as intensifying over time and to “older” workers relative to “younger” workers. Also, common experience indicates that “talk about discrimination because of age is naturally understood to refer to discrimination against the older.”
Thus, the Supreme Court rejected the younger workers’ claims of age discrimination.
Legal Alert Email Disclaimer
Legal Alerts are published by Kronick Moskovitz Tiedemann & Girard as a timely reporting service to alert clients and other friends of recent changes in case law, opinions or codes. This alert does not represent the legal opinion of the firm or any member of the firm on the issues described, and the information contained in this publication should not be construed as legal advice. Should further analysis or explanation of the subject matter be required, please contact the attorney with whom you normally consult.