Law School Case Brief
Gen. Dynamics Land Sys. v. Cline - 540 U.S. 581, 124 S. Ct. 1236 (2004)
The Age Discrimination in Employment Act of 1967, 29 U.S.C.S. § 621 et seq., forbids discriminatory preference for the young over the old. It does not prohibit favoring the old over the young.
A collective-bargaining agreement between a company and a union eliminated the company's obligation to provide health benefits to subsequently retired employees, except as to then-current workers at least 50 years old. Employees (collectively, Cline), who were over 40 years of age but below 50, filed a complaint against the Equal Employment Opportunity Commission (EEOC) alleging that the agreement violated the Age Discrimination in Employment Act of 1967 (ADEA) because it discriminated against them with respect to compensation, terms, conditions, or privileges of employment, because of their age. The EEOC agreed, and invited the company and the union to settle informally with Cline. When they failed, Cline brought an action under the ADEA and state law. The district court dismissed, calling the federal claim one of "reverse age discrimination" upon which no court had ever granted relief under the ADEA, and relying on a Seventh Circuit decision holding that the ADEA does not protect younger workers against older workers. On appeal, the United States Court of Appeals for the Sixth Circuit reversed, reasoning that ADEA's prohibition of discrimination was so clear on its face that if Congress had meant to limit its coverage to protect only the older worker against the younger, it would have said so. The court acknowledged that its ruling conflicted with earlier cases, but criticized those decisions for paying too much attention to the general language of Congress's ADEA findings. The court also drew support from the EEOC's position in an interpretive regulation.
Was the agreement violative the ADEA?
Based upon the ADEA's text, structure, purpose, and history, the United States Supreme Court determined that the ADEA did not prohibit favoring the old over the young. The ADEA was concerned with protecting a relatively old worker from discrimination that worked to the advantage of the relatively young. "Age" meant one thing in 29 U.S.C.S. § 623(a)(1) and another in § 623(f). The Court did not decide the deference issue because the Equal Employment Opportunity Commission was clearly wrong in its interpretation of the ADEA.
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