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In an Age Discrimination in Employment Act case, 29 U.S.C.S. § 621 et seq., plaintiff's prima facie case must include proof of (1) the employee's membership in the protected group, (2) his discharge, (3) his replacement with a person outside the protected group, and (4) his ability to do the job. "Prima facie" refers to evidence sufficient for a finding in plaintiff's favor unless rebutted.
After unsuccessful informal attempts to resolve the dispute, the Secretary of Labor sued appellant Goodyear Tire & Rubber Company ("Goodyear") alleging a violation of the Age Discrimination in Employment Act of 1967 ("ADEA"). The allegation concerned the discharge of William G. Reed, Jr., and appellee sought to enjoin further violations and to recover Reed's lost wages. The district court found the violation alleged and granted the requested relief, including a nationwide injunction against further violations. Goodyear appealed.
Was the evidence sufficient to warrant a nationwide injunction against Goodyear?
The court disagreed that the evidence was sufficient to warrant a nationwide injunction against Goodyear because the evidence was based solely on Reed’s discharge. The court thus vacated the injunction and remanded the case for further consideration of the scope of injunctive relief, recommending that it be limited to the location where the employee had worked. The court held that the district court did not abuse its discretion in deciding not to deduct unemployment benefits from the back pay owed to Reed. The judgment was affirmed in part, vacated in part, and remanded.