Meacham v. Knolls Atomic Power Laboratory (2007)
- Docket
- 06-1505
- Decided
- 2007-01-01
Summary
Question: Under the Supreme Court's decision in Smith v. City of Jackson , must the employer or the employee prove the reasonableness of adverse employment decisions occurring as part of a claim for age discrimination under the federal Age Discrimination in Employment Act? Conclusion: Yes. Writing for a 7-1 majority on the issue of burden of proof, Justice David Souter stated that the text and structure of the ADEA indicated that it is the employer, not the employee, who must bear both the burden of production and the burden of persuasion for the use of "reasonable factors other than age" in the decision to terminate employment. Justice Antonin Scalia concurred in the judgment, suggesting that the Congress left the determination of these issues in the hands of the Equal Opportunity Employment Commission. Justice Clarence Thomas concurred in part and dissented in part. In his brief dissent, Thomas noted his belief that "disparate-impact claims" such as this one, which allege a discriminatory result rather than discriminatory intent, should not be allowed under the ADEA. Justice Stephen Breyer took no part in the decision because he is a significant shareholder in Knolls' parent company.