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Reeves v. Sanderson Plumbing Products, Inc., 530 U.S. 133, 120 S.Ct. 2097 (June 12, 2000)
Keywords: ADEA (wrongful termination, evidence sufficient to survive summary judgment; standard for ruling on a Rule 50 motion for judgment as a matter of law)
Introduction: Roger Reeves sued Sanderson Plumbing Products under the ADEA after he was terminated. The jury found for Reeves. However, the Fifth Circuit reversed using a "pretext plus" standard. The Supreme Court explains what evidence is required to create a jury question under McDonnell Douglas.
Facts: This summary will not focus on the facts of this particular case, but upon the legal conclusions announced by the Supreme Court.
1. A plaintiff's prima facie case, combined with sufficient evidence to find that the employer's asserted justification is false, may permit the trier of fact to conclude that the employer unlawfully discriminated.
2. However, there may be instances where, although the plaintiff has established a prima facie case and set forth sufficient evidence to reject the defendant's explanation, no rational factfinder could conclude that the action was discriminatory.
3. For example, an employer would be entitled to judgment as a matter of law if the record conclusively revealed some other, nondiscriminatory reason for the employer's decision, or if the plaintiff created only a weak issue of fact as to whether the employer's reason was untrue and there was abundant and uncontroverted independent evidence that no discrimination had occurred.
4. With respect to the standard for ruling on a Rule 50 motion for judgment as a matter of law, some courts have held that review is limited to that evidence favorable to the non-moving party. Most courts have held that review extends to the entire record, drawing all reasonable inferences in favor of the nonmovant.
5. The Supreme Court holds that in entertaining a motion for judgment as a matter of law, a court should review all of the evidence in the record. In doing so, however, the court must draw all reasonable inferences in favor of the nonmoving party, and it may not make credibility determinations or weigh the evidence.
6. Click here to see actual case.
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