Reeves v. Sanderson Plumbing Products, Inc.

Brief Fact Summary.

Reeves brought an age discrimination action against Sanderson Plumbing Products, Inc. The district court allowed the matter to be submitted to the jury. The jury returned a verdict for Reeves, finding that Sanderson Plumbing Products, Inc. intentionally discriminated. The Court of Appeals overturned the verdict, finding that the evidence was insufficient as a matter of law to sustain the jury’s finding of intentional discrimination.

Synopsis of Rule of Law.

In an age discrimination case, a prima facie case of discrimination and evidence sufficient to support the trier of fact not believing the defendant’s legitimate nondiscriminatory explanation for its action may support the trier of fact’s determination that an employer unlawfully discriminated, but such a showing will not always be sufficient to sustain a finding of liability.

Facts.

Reeves sued Sanderson Plumbing Products, Inc., alleging age discrimination. The district court allowed the matter to be submitted to the jury. The jury returned a verdict for Reeves, finding that Defendant intentionally discriminated. The Court of Appeals overturned the verdict, however. The Court of Appeals found that where, as here, a plaintiff had presented a prima facie case of age discrimination and sufficient evidence to support the trier of fact not believing the defendant’s legitimate nondiscriminatory reason for the allegedly discriminatory conduct, the evidence was insufficient as a matter of law to sustain a jury’s finding of intentional discrimination.

Issue.

Did the Court of Appeals err in overturning the jury’s verdict and finding that the evidence was insufficient as a matter of law to sustain the jury’s finding of intentional discrimination?

Held.

Yes. The Court of Appeals erred in overturning the jury’s verdict and finding that the evidence was insufficient as a matter of law to sustain the jury’s finding of intentional discrimination.

Discussion.

The Court of Appeals misconstrued Reeves’s evidentiary burden. If the factfinder does not believe the employer’s legitimate nondiscriminatory explanation for its alleged discriminatory conduct, this does not compel judgment for the plaintiff, although it would be permissible for the trier of fact to infer discrimination under such circumstances.  Moreover, on a motion for judgment as a matter of law under Federal Rule of Civil Procedure 50, a court should review all of the evidence in the record, drawing all reasonable inferences in favor of the nonmoving party and uncontradicted and unimpeached evidence supporting the moving party.