Reeves v. Sanderson Plumbing Prods.
Supreme Court of the United States
March 21, 2000, Argued ; June 12, 2000, Decided
[*137] [**2103] [***113] JUSTICE O'CONNOR delivered the opinion of the Court.
This case concerns the kind and amount of evidence necessary to sustain a jury's verdict that an employer unlawfully discriminated on the basis of age. Specifically, we must resolve whether a defendant is entitled to judgment as a matter of law when the plaintiff's case consists exclusively of a prima facie case of discrimination and sufficient evidence for the trier of fact to disbelieve the defendant's legitimate, nondiscriminatory explanation for its action. We must also decide whether the employer was entitled to judgment as a matter of law under the particular circumstances presented here.
In October 1995, petitioner Roger Reeves was 57 years old and had spent 40 years in the employ of respondent, Sanderson Plumbing Products, Inc., a manufacturer of toilet seats and covers. 197 F.3d 688, 690 (CA5 1999). Petitioner worked in a department [****10] known as the "Hinge Room," where he supervised the "regular line." Ibid. Joe Oswalt, in his mid-thirties, supervised the Hinge Room's "special line," and Russell Caldwell, the manager of the Hinge Room and age 45, supervised both petitioner and Oswalt. Ibid. Petitioner's responsibilities included recording the attendance and hours of those under his supervision, and reviewing a weekly report that listed the hours worked by each employee. 3 Record 38-40. [***114]
In the summer of 1995, Caldwell informed Powe Chesnut, the director of manufacturing and the husband of company president Sandra Sanderson, that "production was down" in [*138] the Hinge Room because employees were often absent and were "coming in late and leaving early." 4 id. at 203-204. Because the monthly attendance reports did not indicate a problem, Chesnut ordered an audit of the Hinge Room's timesheets for July, August, and September of that year. 197 F.3d at 690. According to Chesnut's testimony, that investigation revealed "numerous timekeeping errors and misrepresentations on the part of Caldwell, Reeves, and Oswalt." Ibid. Following the audit, Chesnut, along with Dana Jester, vice president of human [****11] resources, and Tom Whitaker, vice president of operations, recommended to company president Sanderson that petitioner and Caldwell be fired. 197 F.3d at 690-691. In October 1995, Sanderson followed the recommendation and discharged both petitioner and Caldwell. 197 F.3d at 691.
In June 1996, petitioner filed suit in the United States District Court for the Northern District of Mississippi, contending that he had been fired because of his age in violation of the Age Discrimination in Employment Act of 1967 (ADEA), 81 Stat. 602, as amended, 29 U.S.C. § 621 et seq. At trial, respondent contended that it had fired petitioner due to his failure to [**2104] maintain accurate attendance records, while petitioner attempted to demonstrate that respondent's explanation was pretext for age discrimination. 197 F.3d at 692-693. Petitioner introduced evidence that he had accurately recorded the attendance and hours of the employees under his supervision, and that Chesnut, whom Oswalt described as wielding "absolute power" within the company, 3 Record 80, had demonstrated age-based animus in his dealings with petitioner. 197 F.3d at 693. [****12] Read The Full CaseNot a Lexis Advance subscriber? Try it out for free.
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530 U.S. 133 *; 120 S. Ct. 2097 **; 147 L. Ed. 2d 105 ***; 2000 U.S. LEXIS 3966 ****; 68 U.S.L.W. 4480; 82 Fair Empl. Prac. Cas. (BNA) 1748; 78 Empl. Prac. Dec. (CCH) P40,045; 2000 Cal. Daily Op. Service 4629; 2000 Daily Journal DAR 6199; 2000 Colo. J. C.A.R. 3474; 13 Fla. L. Weekly Fed. S 406
ROGER REEVES v. SANDERSON PLUMBING PRODUCTS, INC.
Prior History: [****1] ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT.
Disposition: 197 F.3d 688, reversed.
prima facie case, employees, sufficient evidence, matter of law, fired, records, intentional discrimination, trier of fact, attendance, reasons, nondiscriminatory, circumstances, arrived, district court, discriminated, factfinder, supervised, intentionally, nonmovant, proffered, motion for judgment as a matter of law, entitled to judgment, reasonable inference, jury's finding, en banc, recommended, age-based
Business & Corporate Compliance, Disparate Treatment, Statutory Application, Age Discrimination in Employment Act, Labor & Employment Law, Employment Practices, Adverse Employment Actions, Compensation, Discrimination, General Overview, Age Discrimination, Scope & Definitions, Discriminatory Employment Practices, Discharges & Failures to Hire, Evidence, Evidence, Admissibility, Circumstantial & Direct Evidence, Burdens of Proof, Burdens of Proof, Burdens of Production, Burden Shifting, Ultimate Burden of Persuasion, Inferences & Presumptions, Civil Procedure, Trials, Judgment as Matter of Law, Healthcare Law, Business Administration & Organization, Employment Issues, Employment Discrimination, Procedural Matters, Actionable Discrimination, Summary Judgment, Entitlement as Matter of Law, Appeals, Summary Judgment Review, Weight & Sufficiency