Reeves v. Sanderson Plumbing Prods. Inc.

Brief Fact Summary.

Reeves appealed an appellate court finding that he did not present enough evidence to prove intentional discrimination under the Age Discrimination in Employment Act (ADEA) after providing evidence that his supervisor treated him like a child and stated that Reeves was “so old he must have come over on the Mayflower.”

Synopsis of Rule of Law.

A finding for intentional discrimination is sustainable if the fact finder has a reason to reject the employer’s nondiscriminatory reason for it’s decision and the plaintiff established a prima facie case for discrimination.

Facts.

Reeves brought suit against Sanderson Plumbing Prods. Inc. (Sanderson) under the Age Discrimination in Employment Act (ADEA). Sanderson claimed to fire Reeves because of several timekeeping errors and misrepresentations of the department he oversaw; Reeves, however, provided evidence that his supervisor stated that Reeves was “so old he must have come over on the Mayflower” and the supervisor treated Reeves as if he was a child. The trial court granted judgment to Reeves and the appellate court reversed, claiming that Reeves did not present enough evidence to prove intentional discrimination. Reeves appealed.

Issue.

Whether a finding for intentional discrimination is sustainable if the fact finder has a reason to reject the employer’s nondiscriminatory reason for it’s decision and the plaintiff established a prima facie case for discrimination?

Held.

Yes. The judgment of the appellate court is reversed. Reeves presented evidence that his supervisor treated him adversely due to his age, and treated younger employees with patience and respect. Similarly, Reeves properly proved that his employer’s reasons for firing him were false, as Reeves accurately kept time.

Discussion.

Under McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973), a plaintiff alleging intentional discrimination under the ADEA or Title VII, must make a prima facie case for discrimination. The burden then shifts to the employer to prove a nondiscriminatory reason for the adverse employment action. The burden then shifts to the plaintiff to show that the employer’s true reason for the action was discriminatory.