Law School Case Brief
Lineen v. Metcalf & Eddy, Inc. - 96 Civ. 2718 (HB)(MHD), 1997 U.S. Dist. LEXIS 1767 (S.D.N.Y. Feb. 20, 1997)
The party resisting discovery must demonstrate the extent of the burden with some specificity. Courts have not been receptive to broad or reflexive claims of burden, particularly in Title VII litigation.
Deanna Lineen is pursuing this lawsuit against her former employer, Metcalf & Eddy, Inc. ("ME"), alleging that the company violated the Age Discrimination in Employment Act, 29 U.S.C. § 623 et seq., when it terminated her, assertedly because of her age. ME alleged that Lineen's duties were taken over by a newly-hired individual of approximately the same age who was better qualified to handle a broader range of duties. Lineen argued that the explanation proffered was pretextual. In discovery, Lineen sought production of documents reflecting personnel decisions and policies made by ME, its parent company, and several affiliates.
Was ME able to show undue burden with specificity with regard to the discovery sought by Lineen?
The court held that Lineen made a sufficient showing to justify limited discovery from the parent and affiliates based on the close connection between the companies, including some shared employees and facilities. The deposition testimony of the president showed at least some control by the parent company's management over employment decisions of the subsidiaries. The discovery sought by Lineen was therefore presumptively justified. Even if her replacement was of a similar age, Lineen could still point to circumstances suggesting that the termination decision was motivated, in whole or in part, by her age. ME failed to show undue burden with specificity, and courts extended a liberal discovery approach in employment discrimination cases.
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