Meacham v. Knolls Atomic Power Laboratory | |
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Argued April 23, 2008 Decided June 19, 2008 | |
Full case name | Clifford B. Meacham, et al., Petitioners v. Knolls Atomic Power Laboratory, aka KAPL, Inc., et al. |
Docket no. | 06-1505 |
Citations | 554 U.S. 84 ( more ) |
Court membership | |
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Case opinion | |
Majority | Justice David H. Souter |
Laws applied | |
Age Discrimination in Employment Act of 1967 |
Meacham v. Knolls Atomic Power Laboratory, 554 U.S. 84 (2008), was a case decided by the Supreme Court of the United States on June 19, 2008. The Court decided that an employer bears both the burden of production and burden of persuasion when defending a disparate impact claim using the "reasonable factors" defense under the Age Discrimination in Employment Act of 1967 (ADEA). [1] [2]
When Knolls Atomic Power Laboratory (KAPL) conducted a reduction in force in 1996, the employees were assessed based on factors of performance, flexibility, criticality of skills, and years of service. 31 employees were eventually laid off and 30 of them were at least 40 years of age. 26 of these employees filed suit against KAPL asserting, inter alia, disparate impact based on age under the ADEA. At trial, a jury found for the employees on the disparate impact claim and the United States Court of Appeals for the Second Circuit initially affirmed. On appeal, the U.S. Supreme Court vacated the judgment and remanded the case due to its 2005 Smith v. City of Jackson decision. The Second Circuit then vacated its previous decision and held that the petitioners failed to carry their burden of persuasion to prove that KAPL's method of evaluating employees was unreasonable. The employees then appealed to the U.S. Supreme Court. [2] [3]
In a 7–1 decision vacating the Second Circuit's judgment, the Court held that when defending a disparate impact claim using the "reasonable factors other than age" defense under the ADEA, the employer is the one that bears both the burden of production and burden of persuasion. [2] [3]
Board of Trustees of the University of Alabama v. Garrett, 531 U.S. 356 (2001), was a United States Supreme Court case about Congress's enforcement powers under the Fourteenth Amendment to the United States Constitution. The Supreme Court decided that Title I of the Americans with Disabilities Act was unconstitutional, insofar as it allowed states to be sued by private citizens for money damages.
The Age Discrimination in Employment Act of 1967 is a United States labor law that forbids employment discrimination against anyone, at least 40 years of age, in the United States. In 1967, the bill was signed into law by President Lyndon B. Johnson. The ADEA prevents age discrimination and provides equal employment opportunity under the conditions that were not explicitly covered in Title VII of the Civil Rights Act of 1964. The act also applies to the standards for pensions and benefits provided by employers, and requires that information concerning the needs of older workers be provided to the general public.
Griggs v. Duke Power Co., 401 U.S. 424 (1971), was a court case argued before the Supreme Court of the United States on December 14, 1970. It concerned employment discrimination and the disparate impact theory, and was decided on March 8, 1971. It is generally considered the first case of its type.
Disparate impact in the law of the United States refers to practices in employment, housing, and other areas that adversely affect one group of people of a protected characteristic more than another, even though rules applied by employers or landlords are formally neutral. Although the protected classes vary by statute, most federal civil rights laws consider race, color, religion, national origin, and sex to be protected characteristics, and some laws include disability status and other traits as well.
Knolls Atomic Power Laboratory (KAPL) is an American research and development facility based in Niskayuna, New York and dedicated to the support of the US Naval Nuclear Propulsion Program. KAPL was instituted in 1946 under a contract between General Electric and the United States government. In the 21st century, KAPL is a government-owned, contractor-operated laboratory for the US Department of Energy. KAPL is responsible for the research, design, construction, operation, and maintenance of U.S. nuclear-powered warships. It also manages work on nuclear ships at numerous shipyards across the country.
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Disparate treatment is one kind of unlawful discrimination in US labor law. In the United States, it means unequal behavior toward someone because of a protected characteristic under Title VII of the United States Civil Rights Act. This contrasts with disparate impact, where an employer applies a neutral rule that treats everyone equally in form, but has a disadvantageous effect on some people of a protected characteristic compared to others.
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Gross v. FBL Financial Services, Inc., 557 U.S. 167 (2009), was a case decided by the Supreme Court of the United States in 2009, involving the standard of proof required for a claim under the Age Discrimination in Employment Act (ADEA).
In the United States, all states have passed laws that restrict age discrimination, and age discrimination is restricted under federal laws such as the Age Discrimination in Employment Act of 1967 (ADEA). However, it is worthy of note that age discrimination is still an issue in employment as of 2019.
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Gregory v. Ashcroft, 501 U.S. 452 (1991) was a U.S. Supreme Court case. It concerned a provision in the Missouri state constitution that required state judges to retire at the age of 70, and the court was asked to consider whether it conflicted with the 1967 federal Age Discrimination in Employment Act (ADEA) and the Equal Protection Clause of the Fourteenth Amendment to the United States Constitution. The provision was upheld, with the case being one of several Supreme Court decisions supporting the principle that "ambiguous language will not be interpreted to intrude on areas of traditional state authority or important state governmental functions".
Ruan v. United States, 597 U.S. ___ (2022), was a case decided by the Supreme Court of the United States.
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